The U.S. Court of Appeals for the Seventh Circuit affirmed the dismissal of a racial discrimination lawsuit against United Airlines, ruling that passenger Yubo Miao failed to state a plausible claim that he was removed from a flight because of his race.
In the case *Yubo Miao v. United Airlines, Inc.* (7th Cir. 2026), decided Jan. 13, the three-judge panel upheld a lower court's grant of United's motion to dismiss. The decision was argued Dec. 11, 2025, before Circuit Judges Ripple, Scudder, and Kirsch, with Judge Kirsch writing the opinion.
Miao, an American citizen of Chinese descent, filed the lawsuit alleging violations of Title VI of the Civil Rights Act of 1964 and 42 U.S.C. § 1981 after being removed from a United flight from Chicago to San Diego. According to the complaint, Miao boarded the aircraft and was allegedly singled out for harsh treatment by a white flight attendant before ultimately being kicked off the plane.
The incident began when Miao placed his luggage—two suitcases and a lunch bag—in the overhead bin and took his seat. A flight attendant then asked Miao to place his lunch bag under his seat, but Miao instead put it on the empty seat next to him. When the flight attendant asked a second time for Miao to move the lunch bag under his seat, the situation escalated.
The appeals court reviewed the case under the standard for motions to dismiss, accepting all well-pleaded allegations of fact as true and drawing all reasonable inferences in the plaintiff's favor, as established in *Alarm Detection Sys., Inc. v. Village of Schaumburg* (7th Cir. 2019).
Despite this favorable standard for plaintiffs, the Seventh Circuit found that Miao's allegations failed to establish a plausible claim of racial discrimination. The court wrote that "there's no plausible allegation that Miao was discriminated against," leading to the affirmation of the district court's dismissal.
The case originated in the U.S. District Court for the Northern District of Illinois, Eastern Division, where Judge Charles P. Kocoras granted United's motion to dismiss for failure to state a claim. The district court found that Miao's complaint did not contain sufficient factual allegations to support his discrimination claims.
Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in programs and activities that receive federal financial assistance. Section 1981, meanwhile, provides broader protection against racial discrimination in the making and enforcement of contracts, including commercial transactions like airline tickets.
For a discrimination claim to survive a motion to dismiss, plaintiffs must plead facts that, if true, would plausibly suggest discriminatory intent or treatment. Courts examine whether the alleged conduct could reasonably be attributed to discriminatory animus rather than legitimate, non-discriminatory reasons.
The Seventh Circuit's decision reflects the challenging burden plaintiffs face in discrimination cases, particularly when alleging disparate treatment based on isolated incidents. Airlines routinely enforce policies regarding carry-on items and passenger compliance with crew instructions, creating legitimate business justifications for removal decisions.
The ruling joins a body of case law addressing discrimination claims against airlines, an industry subject to extensive federal regulation and safety requirements. Airlines maintain broad authority to remove passengers for safety, security, or compliance reasons, though this authority cannot be exercised in a discriminatory manner.
Miao's case highlights the difficulty of proving discriminatory intent in situations where airlines can point to policy violations or safety concerns as justification for their actions. The appeals court's finding that no plausible discrimination allegation existed suggests the complaint failed to establish sufficient facts linking the treatment to racial bias.
The decision also underscores the importance of detailed factual pleading in discrimination cases. Under federal pleading standards established by the Supreme Court's decisions in *Bell Atlantic Corp. v. Twombly* and *Ashcroft v. Iqbal*, plaintiffs must include enough factual content to allow courts to draw reasonable inferences that defendants are liable for misconduct alleged.
For United Airlines, the victory provides protection against what it likely viewed as an unfounded discrimination claim. The airline industry faces regular scrutiny over passenger treatment, making successful defense of discrimination allegations significant for operational consistency.
The case demonstrates how federal appeals courts evaluate discrimination claims in the transportation context, requiring plaintiffs to present compelling evidence that adverse treatment stemmed from protected characteristics rather than legitimate policy enforcement or safety considerations.
While the specific details of Miao's interaction with the flight crew were not fully elaborated in the available portions of the opinion, the court's conclusion that no plausible discrimination occurred suggests the alleged conduct fell short of establishing racial bias as the motivating factor for his removal from the aircraft.