Morales v. Trans World Airlines, Inc. (1991)
- Docket
- 90-1604
- Decided
- 1991-01-01
Summary
Question: Does the Airline Deregulation Act of 1978 prevent states from prohibiting deceptive airline fare advertisements through enforcement of their general consumer protection statuses? Conclusion: Yes. Justice Antonin Scalia delivered the opinion of the 5-3 majority. The Court held that the ADA prevents the enforcement of the NAAG fare-advertising guidelines through a state’s general consumer protection. When the ADA was enacted, Congress intended to prevent the state enforcement action if it has a connection with, or references airline rates, routes, or services, including advertisements. The NAAG guidelines explicitly refer to the rates within the meaning of the ADA and would have a significant impact on the airline’s ability to market their product and upon the fares they charge. Justice John Paul Stevens wrote a dissenting opinion in which he argued the words “relate to” in the ADA should not be given a broad meaning because it gives the ADA pre-emption provision a meaning beyond the words and the legislative history behind the enactment. Justice William H. Rehnquist and Justice Harry A. Blackmun joined the dissent Justice David H. Souter took no part in the consideration or decision of the case.