Hammarquist v. United Cont'l Holdings, Inc., No. 15-1836 (7th Cir. 2016)
Annotate this CaseAfter its 2010 merger with Continental Airlines, United Airlines made changes to its frequent‐flier rewards program. In 2014, a member of United’s MileagePlus rewards program claimed that United breached a contract by reducing his anticipated program benefits. The Seventh Circuit concluded (Lagen decision) that the reduction of benefits was not a breach of contract because the program rules allowed United to change the benefits at any time. The plaintiffs in this case also sued for breach of contract. Relying on Lagen, the district court granted summary judgment to United. The Seventh Circuit affirmed, rejecting arguments that the case was different from Lagen because it concerned changes to the “Premier” status program. United did promise to provide the plaintiffs with premier benefits in 2012 that matched the premier benefits previously available in 2011 and cannot be liable for breaching a contract that it did not make.
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