United States Supreme Court
Northwest, Inc. v. Ginsberg, 12-462
In an action alleging that defendant-airlines violated the duty of good faith and fair dealing when it terminated plaintiff's membership in its frequent flyer program, the Ninth Circuit's conclusion that the claim was not preempted by the Airline Deregulation Act of 1978 (ADA) is reversed and remanded, where: 1) the ADA preempts a state-law claim for breach of the implied covenant of good faith and fair dealing if it seeks to enlarge the contractual obligations that the parties voluntarily adopt; 2) plaintiff's claim clearly has a connection with or reference to airline prices, routes, or services; and 3) because plaintiff's implied covenant claim seeks to enlarge his contractual agreement with defendants, it is preempted by the ADA.
- Decided 04/02/2014
- Published 04/02/2014
- United States Supreme Court