Demonstrates that the Warsaw Convention, properly interpreted, creates a liability limitation which is legal and not contractual. The Convention's limits apply, by its terms, to any cause of action arising out of injury in international air transportation regardless of whether it is founded in contract or in tort or in any other manner.
Mark S. Flynn,
The Interpretation of the Warsaw Convention in Wrongful Death Actions,
3 Fordham Int'l L.J. 71
Available at: http://ir.lawnet.fordham.edu/ilj/vol3/iss1/3