Federal appeals court rules that “nonrefundable” means . . . nonrefundable

Martin v. United Airlines, Inc. (10th Cir. Feb. 21, 2018).  After buying several “nonrefundable” tickets via United’s website, the customers/plaintiffs, a married couple, canceled their reservations before the ticketed departure dates.  They alleged they attempted, without success, to make new reservations within the one-year deadline set forth in United’s Contract of Carriage for booking a new flight, and subsequently, to get United to extend such deadline. The customers filed a class action complaint in an Oklahoma state court, alleging causes of action for (1) “breach of contract by failure of consideration,” (2) “breach of contract by failure to fulfill reasonable expectations,” (3) “recovery of money wrongfully kept,” and (4) “tortious breach of the covenant of good faith.”  The customers conceded that, in buying the tickets, they had agreed to the CoC, which they described as…

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