Join Date: Oct 2000
Location: Munich, Germany
Programs: LH HON, DL FO/MM, Marriott Lifetime Platinum, Accor Lifetime Platinum, Sixt Diamond
Posts: 6,174
The published check-in time limit for all US destinations ex Zurich is 70 minutes, for all classes of service.
Looks like a case of IDB (if the passenger is able to prove that he was at the check-in counter 1:10 prior to departure, and not 1:09 or less). A refund of the $200 plus IDB compensation would be due then.