The Bottom Line
- Airlines are not automatically liable for missed connections if the passenger’s remaining transfer time technically meets the airport’s official Minimum Connection Time (MCT).
- The burden of proof can shift to the passenger. If an airline demonstrates that a connection was theoretically possible, the passenger must provide concrete evidence showing why it was practically impossible to make the flight.
- Operational data is key. This ruling underscores the importance of precise timings (“blocks on” vs. “doors open”) and highlights that mere assertions without supporting evidence are insufficient to win a compensation claim.
The Details
This case involved a passenger traveling from Amsterdam to Managua, Nicaragua, via Madrid and Miami with Iberia. The second leg of the journey, from Madrid to Miami, was delayed. As a result, the passenger and her child missed their connecting flight in Miami and ultimately arrived at their final destination more than three hours late. Citing EU Regulation 261/2004, the passenger claimed €1,200 in compensation for the long arrival delay, a situation that typically warrants a payout.
The airline, Iberia, mounted a successful and nuanced defense. It acknowledged the initial flight arrived in Miami 48 minutes late but argued that this was not the cause of the missed connection. The flight landed at 15:48, and the connecting flight was scheduled for 17:20, leaving a transfer time of 92 minutes. Crucially, the official Minimum Connection Time (MCT) for that specific transfer at Miami airport is 90 minutes. Because the available time exceeded the MCT, Iberia contended that the passenger still had a sufficient window to make her next flight, and therefore the airline was not responsible for the consequences.
The District Court of Noord-Holland sided with the airline, basing its decision on the burden of proof. While the passenger correctly argued that the legal arrival time is when the aircraft doors open, not when the plane reaches the gate (“blocks on”), she failed to substantiate her claim that this made the connection impossible. The court ruled that once the airline presented a plausible defense—that the MCT was met—the onus shifted to the passenger to prove that the delay made catching the next flight impossible. Her simple assertion that the doors could not have opened in time was deemed insufficient evidence. As the passenger failed to meet this burden, the court concluded that the airline was not at fault and dismissed the claim.
Source
Source: Rechtbank Noord-Holland
