Article: Recoverable damages in wrongful death actions governed by the Warsaw Convention.

THE most significant recent development in Warsaw Convention jurisprudence in the United States is the application of federal common law, rather than state or foreign law, to wrongful death damage actions governed by the convention. There are two key questions raised by this newly developing body of law:

* What type of damages may properly be recovered in wrongful death actions governed by the Warsaw Convention?

* Who is entitled to recover such damages?

Article 17 of the Warsaw Convention(1) creates a cause of action for "damage sustained" in the event of "death," "wounding," or other "bodily injury" of a passenger. The convention is silent, however, ...

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