The U.S. Court of Appeals for the Seventh Circuit affirmed the dismissal of a racial discrimination lawsuit filed by passenger Yubo Miao against United Airlines, finding no plausible allegations that the airline discriminated against him based on his race.
In the January 13, 2026 decision in *Miao v. United Airlines, Inc.*, a three-judge panel unanimously upheld the Northern District of Illinois' grant of United's motion to dismiss. Circuit Judge Kirsch wrote the opinion for the court, with Circuit Judges Ripple and Scudder joining.
Miao, an American citizen of Chinese descent, alleged that after boarding a United Airlines flight from Chicago to San Diego, he was singled out for harsh treatment by a flight attendant and ultimately removed from the aircraft because of his race. He filed suit under Title VI of the Civil Rights Act of 1964 and 42 U.S.C. § 1981, federal statutes that prohibit racial discrimination.
According to the complaint, as Miao walked down the aisle after boarding, a white flight attendant stared at him. Miao then placed his luggage—consisting of two suitcases and a lunch bag—in an overhead bin and took his seat. The flight attendant asked Miao to place his lunch bag under his seat, but instead Miao put the bag on an empty seat next to him.
The flight attendant made a second request for Miao to move his lunch bag under his seat, but the court opinion indicates Miao refused this instruction as well. The complaint alleged that this interaction escalated, ultimately resulting in Miao being removed from the flight.
The district court, presided over by Judge Charles P. Kocoras, granted United Airlines' motion to dismiss the case for failure to state a claim upon which relief can be granted. This procedural ruling means the court found that even accepting all of Miao's allegations as true, he failed to establish a viable legal claim for racial discrimination.
On appeal, the Seventh Circuit applied the standard for reviewing motions to dismiss, accepting all well-pleaded allegations of fact as true and drawing all reasonable inferences in the plaintiff's favor. The court cited *Alarm Detection Systems, Inc. v. Village of Schaumburg* (7th Cir. 2019) for this principle.
Despite applying this favorable standard to Miao's case, Circuit Judge Kirsch concluded that "there's no plausible allegation that Miao was discriminated against." The court's brief opinion suggests that the facts alleged by Miao, while potentially frustrating, did not rise to the level of actionable racial discrimination under federal law.
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving federal financial assistance. Section 1981, enacted during Reconstruction, guarantees all persons the same right to make and enforce contracts as enjoyed by white citizens, and has been interpreted to apply to various commercial relationships including airline passenger service.
To succeed on either claim, Miao would need to demonstrate that United Airlines' actions were motivated by racial animus rather than legitimate business or safety concerns. Airlines have broad authority to remove passengers for various reasons, including failure to comply with crew instructions or safety regulations.
The case highlights the challenging burden plaintiffs face when alleging discrimination based on airline personnel decisions. Courts generally defer to airline crew judgment on passenger removal decisions, particularly when safety or compliance issues are involved.
The appeals court heard oral arguments in the case on December 11, 2025, and issued its decision approximately one month later on January 13, 2026. The expedited timeline suggests the panel viewed the legal issues as relatively straightforward.
For Miao, the affirmance represents the end of his federal court challenge unless he seeks review by the Supreme Court, which would be unlikely given the case's specific factual circumstances and the lack of any apparent circuit split on the relevant legal principles.
The decision also provides guidance for future discrimination claims against airlines, reinforcing that plaintiffs must present more than allegations of disparate treatment to survive a motion to dismiss. Courts require plausible allegations that race was a motivating factor in the airline's actions.
United Airlines, represented in the case as defendant-appellee, successfully defended against both the original district court action and the subsequent appeal. The airline industry faces various discrimination claims, making precedents like *Miao* important for establishing the boundaries of actionable conduct.
The Seventh Circuit's jurisdiction includes Illinois, Indiana, and Wisconsin, meaning this precedent will guide future discrimination cases against airlines in those states. However, the decision's reasoning may influence courts in other circuits facing similar fact patterns involving alleged discriminatory treatment of airline passengers.