Tuesday, February 17, 2026
Page 3
Ninth Circuit:
Link Between Damaged Wheelchair, Death, Too Tenuous
By a MetNews Staff Writer
The Ninth U.S. Circuit Court of Appeals yesterday declined to upset a summary judgment in favor of United Airlines, rejecting the plaintiffs’ contention that damage to a wheelchair during a return flight to Los Angeles from the District of Columbia proximately caused the death of the plaintiffs’ sister.
Decedent Engracia Figueroa had been rendered a quadriplegic by virtue of a t1992 rain accident. Her wheelchair was highly specialized.
Upon landing at LAX, it was discovered that the joystick had been damaged. United offered to have it repaired but Figueroa insisted on using a shop with which she was familiar.
Allegations of Complaint
Suit was brough following her death three months later, with the plaintiffs asserting that Figueroa’s demise was attributable to her being unable to find a suitable replacement wheelchair. The complaint, filed in Alameda Superior Court—with the action removed by United to federal court—alleges:
“[D]uring the 37 days when UNITED was refusing lo provide a replacement chair, ENGRACIA’s condition deteriorated rapidly. The pressure sore further opened up as a direct result of ENGRACIA sitting on a chair not customized for her and lacking proper extension for her leg. She also began experiencing cramps and pain in her upper body as a result of sitting in the wheelchair without proper support.”
A replacement wheelchair was supplied on Oct. 2, 2021 but, the pleading says, “the chair was provided without the needed extension for ENGRACIA’s leg.”
After visits to the hospital, Figueroa died Oct. 31, 2021.
District Court Judge Rita F. Lin of the Northern District of California granted summary judgment in favor of the airline.
United argued on appeal that the plaintiffs “sought to establish a causal connection between the two temporally and substantively disparate events: the damaged wheelchair and Figueroa’s death.”
Ninth Circuit’s Decision
A Ninth Circuit panel—comprised of Circuit Judges Jacqueline H. Nguyen and Gabriel P. Sanchez, joined by Senior Circuit Judge N.R. Smith—agreed, saying:
“It is undisputed that United owed Figueroa a duty to return her wheelchair in its original condition and breached that duty by failing to do so. United” s breach, however, was too attenuated from Figueroa’s injury to satisfy the proximate cause requirement….Although Appellants presented evidence that Figueroa’s wheelchair was highly customized, there is no evidence that properly-fining wheelchairs were scarce or difficult to obtain, or that damage to a wheelchair generally poses a risk of serious injury or death due to replacement difficulties.”
The judges declared that “the ultimate harm here resulted from intervening acts not reasonably foreseeable from the alleged breach.”
The case is Porter v. United Airlines, 24-6964.
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