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Did an airline’s negligence result in a dangerous condition on a jet bridge? – Guntur v. Jetblue Airways Corp., 2011 NY Slip Op 32615 (N.Y. Sup. Ct., 2011)


In this slip and fall case, the issue is whether an airline caused the hazardous condition or had notice of the hazardous condition that led to the plaintiff’s injuries.

Plaintiff Guntur was scheduled to fly from Logan Airport in Boston to New York. While she was in the restroom, her name was called for boarding. She hurried back to the gate and down the jet bridge as she did not want to miss the flight. She was the last to board the plane. As she neared the portion of the jet bridge that connected with the door of the airplane, Guntur slipped and fell. She immediately looked at the area where she fell and noticed that there was icy, wet dirt. Guntur filed a lawsuit against Jetblue to recover damages for the injuries she suffered due to her fall that was caused by Jetblue’s negligence.

The Airport Operations Lead Officer for the airline testified that the airplane was regularly cleaned. On icy or rainy days, the airplane was cleaned not only by the cleaning crew but the flight attendants check the jet bridge for any water or snow accumulation. The employees have a broom and mop handy. They also have a carpet that they lay so that the passengers can walk on a dry surface. The flight attendants are also trained to always check the entrance of the plane. They are trained to use handy paper towels to pat the area dry so that the passengers will walk onto the plane on a dry surface.

The flight attendant who assisted the plaintiff testified in a deposition that she told plaintiff Guntur not to run as she was not going to miss the flight, but Guntur did not break her pace. The flight attendant also testified that at the time of the incident there was snow blowing. She stated that although she did not observe a wet area, the canopy from the jet bridge did not make a tight seal around the plane’s door so that sometimes rain water and snow would come in.

Defendant Jetblue moved for summary judgment, arguing that there was no evidence that Jetblue created the condition which caused Guntur’s slip and fall accident or had notice of the condition. As evidence to support their motion, the airlines attached the deposition testimonies not only of the plaintiff but also the operations officer and the flight attendant. The airlines also attached a copy of the incident report and of the weather reports on that day. On the other hand, Guntur argued that the hazardous condition was caused by the lack of a tight seal between the jet bridge and the plane entrance.

The Court ruled in favor the defendant, noting that there is no evidence that the airlines created the dangerous condition which caused the plaintiff to slip and fall. The fact that there was a foreign substance such as snow or rain water is not sufficient to prove negligence on the part of the airlines. In addition, there is no evidence that Jetblue’s employees had actual or constructive knowledge of the icy, wet condition.

Accidents that result in serious injuries are common in not only airports and airplanes, but in stores, homes, and other premises. Guntur v. Jetblue Airways Corp., shows that it is important to understand that just because you are injured on someone’s property, does not mean that the property owner or manager is legally liable and must pay you damages. In order for liability to attached, there must have been a dangerous condition on the property. In addition, the property owner must have created the dangerous condition or must have had actual or constructive notice of the condition. Constructive notices means that the hazardous condition was apparent and existed long enough for the property owner to have noticed it.

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