Edna Christensen v. Northwest Airlines, Inc.

Appellant Christensen seeks damages allegedly arising from being denied seats (“bumped”) on her reserved flight from Spokane to Seattle, and for mental distress arising from a short verbal altercation with a Northwest Airlines agent. The District Court, in a published summary judgment order, dismissed her action for failure to meet the $10,000 amount-in-controversy jurisdictional requirements of 28 U.S.C. §§ 1331 (a), 1332(a). See Christensen v. Northwest Airlines, Inc., 455 F.Supp. 492 (D.Haw.1978). We affirm.

A full statement of the facts, appellant’s allegations, and applicable law are set forth in the District Court opinion. In short, on June 25, 1974, Christensen and her children were bumped on their reserved flight from Spokane to Seattle. Her ultimate destination was Hilo, Hawaii. Northwest Airlines, appellee herein, promptly arranged for alternative transportation, providing appellant first class transportation from Spokane to San Francisco, where appellant then caught a connecting flight to Hilo. In all, Christensen was delayed approximately one hour and thirty-eight minutes from her expected arrival time in Hawaii.

Approximately three years after these events, on June…