Merely claiming that physical injuries led to psychological problems in the aftermath of an airplane accident is insufficient for recovery under the Warsaw Convention, a Southern District judge has ruled.

Addressing an issue on which the U.S. Court of Appeals for the Second Circuit has been silent, Judge Michael B. Mukasey found that a plaintiff hurt during an airline evacuation failed to show the required nexus between his injuries and his ensuing psychological trauma in Alvarez v. American Airlines, 98 Civ. 1027.