Trazius Avrissaint, et al v. Sarasota Manatee Airport Authority
- Case Type:
- Business
- Case Status:
- Affirmed
- Citation:
- 25-11129 (11th Circuit, Aug 18,2025) Not Published
- Tag(s):
-
- Ruling:
- The Eleventh Circuit upheld the rulings of the bankruptcy court and district court, finding that taxi drivers lacked standing to pursue breach of contract claims against airport authority arising from agreement with the debtor, SRQ Taxi, and that the drivers were not third-party beneficiaries of the agreement.
- Procedural context:
- The debtor and twenty-two taxi drivers initiated an adversary proceeding against the Sarasota Manatee Airport Authority, alleging claims for breach of contract. The bankruptcy court concluded that the Sarasota Manatee Airport Authority breached the contract with the debtor, but the debtor and drivers failed to establish damages, and the drivers lacked standing. On appeal to the district court, the taxi drivers argued that they were intended third-party beneficiaries of the agreement. The district court affirmed the ruling of the bankruptcy court, and the drivers appealed.
- Facts:
- SRQ Taxi sought relief under chapter 11 of the Bankruptcy Code, and the debtor and taxi drivers initiated an adversary proceeding against the Sarasota Manatee Airport Authority. The breach of contract claims arose from the debtor and drivers' contention that the SRQ Taxi had the "exclusive right to provide on-demand, fore-hire transportation" and Sarasota Manatee Airport Authority violated that right by allowing other transportation network companies, such as Uber, to pickup passengers from the airport, giving the companies reserved spaces in short term parking, and adding signs directing passengers to pickup areas. The bankruptcy court found that the Sarasota Manatee Airport Authority violated the exclusive right and was liable to SRQ Taxi for damages, but the testimony of the SRQ Taxi's expert witness was stricken, and the debtor failed to establish damages. The bankruptcy court also ruled that the drivers lacked standing and were not third party beneficiaries of the agreement. Judgment was entered in favor of the Sarasota Manatee Airport Authority.
- Judge(s):
- Branch, Anderson, and Wilson
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