Gary Ehrlich and Maryanne Ehrlich v. American Airlines, Inc., American Eagle Airlines, Inc. And Simmons Airlines, Inc.

MESKILL, Circuit Judge.

Plaintiffs-appellants Gary and Maryanne Ehrlich (the Ehrlichs) experienced an ordeal that few airline passengers have the misfortune to endure. While traveling from Baltimore, Maryland to John F. Kennedy International Airport (JFK) to catch a connecting flight to London, the Ehrl-ichs’ plane suffered an abnormal landing. On approaching JFK, their aircraft overshot the runway and was abruptly stopped by an arrestor bed before the plane would otherwise have plunged into the waters of nearby Thurston Bay. 1

According to the Ehrlichs, both appellants sustained physical and…