In Rosman v. Trans World Airlines, Inc., the New York Court of Appeals held that article 17 of the Warsaw Convention limits recovery for personal injuries to objective bodily injury caused by psychic trauma, physical circumstances, or physical impact, and thus, prohibits recovery for psychic trauma alone.
Boone, Joseph William
"International Air Carriers--Psychic Injury and the Warsaw Conventions,"
Mercer Law Review: Vol. 27:
2, Article 11.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol27/iss2/11