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Air Transport Ass'n of America, Inc. v. Cuomo

Court of Appeals for the Second Circuit
2008 WL 763163, 2008 U.S. App. LEXIS 6130, 520 F.3d 218 (2008)
ELI5:

Rule of Law:

The express preemption provision of the Airline Deregulation Act of 1978 (ADA) bars states from enacting laws related to the prices, routes, or services of an air carrier. This preemption extends to state laws mandating specific amenities for passengers during lengthy ground delays, as such requirements constitute a regulation of airline "service."


Facts:

  • During the winter of 2006-2007, several well-publicized incidents occurred in which airline passengers endured lengthy delays while grounded on New York runways.
  • In some of these incidents, passengers were not provided with basic provisions such as food or water.
  • In response, the New York legislature enacted the Passenger Bill of Rights (PBR).
  • The PBR required that whenever an aircraft with boarded passengers was delayed on the ground for more than three hours, the airline carrier must provide electric generation for fresh air and lights, waste removal for restrooms, and adequate food and drinking water.

Procedural Posture:

  • The Air Transport Association of America ('Air Transport') filed suit against New York state officials in the United States District Court for the Northern District of New York.
  • Air Transport sought declaratory and injunctive relief to block the enforcement of the New York Passenger Bill of Rights (PBR).
  • Air Transport moved for summary judgment in the district court.
  • The district court denied Air Transport's motion and granted summary judgment sua sponte (on its own initiative) to the New York officials (Appellees), holding the PBR was not preempted.
  • Air Transport (Appellant) appealed the district court's decision to the United States Court of Appeals for the Second Circuit.

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Issue:

Does the express preemption provision of the Airline Deregulation Act of 1978, which bars state laws 'related to a price, route, or service of an air carrier,' preempt a New York State law requiring airlines to provide passengers with food, water, electricity, and functional restrooms during lengthy ground delays?


Opinions:

Majority - Per Curiam

Yes, the express preemption provision of the Airline Deregulation Act of 1978 preempts the New York Passenger Bill of Rights. The court reasoned that the ADA's preemption clause, 49 U.S.C. § 41713(b)(1), broadly prohibits any state law 'related to a price, route, or service of an air carrier.' The court adopted a broad definition of 'service,' concluding that it encompasses not just the physical transportation but also amenities and the overall passenger experience, including the provision of food, water, electricity, and functional restrooms during ground delays. The court heavily relied on Supreme Court precedent in Morales and Rowe, which interpreted the ADA's preemption clause expansively to ensure that market forces, not a 'patchwork of state service-determining laws,' govern the airline industry. New York's law directly substitutes its own commands for competitive market forces in determining the services airlines must provide, which is precisely what the ADA was designed to prevent. The court also rejected the argument that the PBR was a public health and safety regulation immune from preemption, stating that onboard amenities, whether necessities or luxuries, still 'relate to airline service' and fall within the express terms of the ADA's preemption provision.



Analysis:

This decision significantly reinforces the broad preemptive scope of the Airline Deregulation Act, limiting states' ability to regulate the passenger experience, even on humanitarian grounds. By defining 'service' to include onboard amenities during ground delays, the court effectively centralizes the authority to create such passenger protection rules at the federal level with the Department of Transportation. The ruling signals that any state-level attempts to legislate airline service standards, regardless of their intent, are likely to be struck down, thereby preserving a nationally uniform, market-driven regulatory environment for the airline industry as intended by Congress.

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