Franklin Mint Corporation v. Transworld Airlines - U.S. Ct. of Appeals (2nd Circuit) (Oakes, Cardamone and Winter C.JJ.) - 28 September 1982

U.S. Court of Appeals declines to enforce Warsaw Convention liability limits

TWA sought to limit its liability under Article 22 of the Warsaw Convention for the loss of a cargo of coins. Article 22 limits a carrier’s liability in terms of a specified number of gold or “Poincarí” francs, a unit of account consisting of “65½ milligrams of gold at a standard fineness of nine hundred thousandths”. The question was - what unit of account was now to be used to convert judgments under the Convention into U.S. dollars? At first instance, the parties had offered four alternatives: