On Friday, Gloryanna Samuel sued American Airlines alleging that their wheelchair attendant abandoned her at a gate in Miami, that she missed her flight as a result, and she was left to spend the night in a chair in a cold room at the airport as a result.
Since then she’s had swelling, arm pain and elevated blood pressure which aggravates pre-existing medical conditions. The case is Samuel v. American Airlines, Inc. & Envoy Air, Inc., No. 1:2025‑cv‑00037, U.S. District Court for the District of the Virgin Islands.
- In April 2025, Samuel booked St. Croix – Miami – Tampa on American and requested wheelchair assistance due to multiple medical conditions.
- After landing at Miami International Airport, an Envoy wheelchair attendant initially assisted, but allegedly abandoned her in the chair at the gate for her Tampa flight. Left there, she missed the flight.
- She was rebooked for the next morning. She asked for a hotel, but was told no – and she says she was directed to a cold public room in the airport and slept in a chair overnight, which caused swelling in her feet and eyes; left‑arm pain from propping her head through the night; and elevated blood pressure, which aggravated pre‑existing conditions.
Federal rules require prompt boarding, deplaning and connecting assistance; assistance “in moving within the terminal” from gate to gate, ticketing to gate, gate to baggage claim, etc. Assisted passengers can’t be left unattended in a wheelchair for more than 30 minutes.
There’s no private right of action under the Air Carrier Access Act. Enforcement is via the Department of Transportation. However, state law negligence claims generally go forward.
- American probably tries to argue that wheelchair assistance is a “service” so state claims are pre-empted by the Airline Deregulation Act, but that’s an uphill battle where this case was filed. The U.S. Virgin Islands are covered by the Third Circuit Court of Appeals and Elassaad v. Independence Air there clearly allows state claims for wheelchair service against an airline.
See also Abdullah v. American Airlines in the Third Circuit that suggests while state law cannot trump federal rules on standards for air safety, state (and territory) damage remedies still apply.
The events occurred in Miami so I expect a motion to transfer to the Southern District of Florida, or to Delaware (where American and Envoy Air are incorporated) or Texas (principal place of business).
The 11th Circuit (Florida) is much friendlier to a federal pre-emption argument, as is the 5th Circuit (Texas). In the Southern District of Florida, American successfully argued that assistance with wheelchair and prosthetics during boarding constitues “services” where state law is preempted. (Mennella v. American Airlines.)
- American should focus on pre‑existing conditions, and challenge medical evidence tying one night in a cold room to lasting injuries. Depending on what’s in security footage, they may seek to argue that she left the gate, declined offered assistance, or could have requested more assistance sooner.
American doesn’t have a duty to provide a hotel. There’s nothing in Part 382 requiring it for a missed connection or other assistance failure. The breach here is abandonment at the gate – lack of hotel is just bad optics.
If discovery shows she was left unattended beyond 30 minutes, and missed the connection as a result, then she is likely to succeed demonstrating breach of the airline’s duties.
But showing significant physical injury or lasting impairment directly resulting from the abandonment is going to be tough – perhaps prompting a modest settlement because this looks bad and there’s a sympathetic victim, but not a big payout.
Last year American was fined $50 million over its mishandling of disabled passengers and wheelchairs. They are consistently worst in the industry with wheelchairs, though here it’s ground service rather than lost or damaged chairs at issue. At many stations they outsource wheelchair service (to companies like Prospect, Menzies, G2) but in Miami I believe that service is provided directly by wholly-owned regional carrier Envoy Air. Outsourcing, though, wouldn’t be a defense since the regulatory obligation to ensure the service is provided remains with the airline.
There’s no excuse for the abandonment, but this doesn’t make sense to me:
“After landing at Miami International Airport, an Envoy wheelchair attendant initially assisted, but allegedly abandoned her in the chair at the gate for her Tampa flight. Left there, she missed the flight.”
If she was at the gate, with a boarding pass, how is she not calling out for assistance to get on the plane? I am not blaming her, just asking, cause this doesn’t make sense to me.
Nope…… lame excuses aren’t gonna work on this one, AA…….time to break out the checkbook.
Sadly, wheelchair service is worse at MIA. I am a CK, however, that status does not help when it comes to wheelchairs. Recently on a paid first class international at a cost of over $7000, I did not get service at LHR and was told by AA personnel that I needed to walk to an area to get a wheelchair. I told them if I could walk that far, then I wouldn’t need a WHCR. When I complained to AA customer service, they claimed that I refused a WHCR and didn’t request it on booking, both of which are false. My booking showed request for assistance and I did not refuse the chair.
I am a loyal AA traveler and have managed to have CK for 3 years now! That will not change my opinion but AA really needs to get their act together on providing assistance to those that need it and take responsibility when not provided!
Entitled to some compensation? Yes. Entitled to sue for millions…no.
Sitting in a chair for one night in a cold room is not enough to cause permanent harm. If the passenger or her attorney are claiming otherwise they are wrong. And, quite honestly, if she’s that fragile that a misconnection could cause this many medical maladies, maybe she shouldn’t be flying in the first place.
Plus the story of being abandoned at the gate doesn’t fly with me. She could have gotten someone’s attention. They always page for missing passengers at final boarding. Plus, they would have seen in her itinerary that she’s wheelchair assist. Then again, it’s AA, so who can really say?
The airlines have made me someone who now hates flying and is triggered easily at the airport (which I contain). Should I use AA, DL and UA for PTSD? I’m sure I could get some healthcare professional to say I have it.
Since this occurred at the airport and not in an airplane, the ADA may come into play. The passenger should have brought something to help assure she would be comfortable with any situation that could happen. I always take a winter jacket with me. It has helped when the airplane cabin temperature has been set too low.