Settlements in Germanwings case likely to vary with nationality, say lawyers

New York

THE extraordinary circumstances that led to last week's crash of the Germanwings jet, where a pilot seemingly brought down an airplane, killing everyone aboard, means that the airline's insurers could end up paying hundreds of millions of dollars to the victims' families, according to legal experts.

But while the airline is responsible for the actions of its pilot, not all relatives will be entitled to the same payout. The families of the three American victims, for instance, are likely to get a larger payment from the airline than other passengers because courts in the US usually award larger compensation than European courts.

Under the 1999 Montreal Convention, an international treaty that governs airplane liability, airlines are responsible in cases of accidental death or injury on international flights, and must pay families up to about US$170,000 per victim. The definition of an accident is broad and includes a…