American Airlines, Inc. v. Wolens (1994)
- Docket
- 93-1286
- Decided
- 1994-01-01
Summary
Question: Does the Airline Deregulation Act of 1978 preempt a state-court suit, brought by participants in an airline's frequent flyer program, challenging the airline's retroactive changes in terms and conditions of the program? Conclusion: Yes. In a 6-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the ADA bars state-imposed regulation of air carriers, thus claims brought under a state's consumer fraud act are preempted; but that the ADA allows room for court enforcement of contract terms set by the parties themselves, which permits breach of contract claims to proceed. "A remedy confined to a contract's terms simply holds parties to their agreements -- in this instance, to business judgments an airline made public about its rates and services," wrote Justice Ginsburg. Justice John Paul Stevens filed an opinion concurring in part and dissenting in part. Justice Sandra Day O'Connor filed an opinion concurring in the judgment in part and dissenting in part, which was joined by Justice Thomas Clarence. Justice Antonin Scalia took no part in the decision of the case.