Before boarding an El Al Israel Airlines fl ight from New York to Tel Aviv, Tseng, a passenger, was physically subjected to an intrusive security search.

Although not injured bodily, Tseng sued El Al for damages, asserting, among other charges, assault and false imprisonment. A federal court dismissed the case on the basis of the Warsaw Convention, a treaty that precludes a passenger from maintaining an action for damages resulting from personal injury when the claim does not satisfy certain conditions for liability. The Convention expressly does not “permit recovery for psychic or psychosomatic injury.” Will Tseng be successful in her suit? [ El Al Israel Airlines, Ltd. v. Tsui Yuan Tseng, 122 F.3d 99, reversed.]