American Lung Ass'n v. Environmental Protection Agency

How later courts describe this case

• finding no accident, because the events did not constitute risks inherent in air travel, even though plaintiff alleged that airline personnel had assisted in smuggling and transporting a passenger on a flight out of the country in violation of a court order
• "Generally, more than a temporal connection between the protected conduct and the adverse employment action is required to present a genuine factual issue on retaliation."