Melvin O'Carroll v. American Airlines, Inc., Chaparral Airlines, Inc.

Summary

The Fifth Circuit held that the plaintiff's state-law claims arising from his removal from an airline flight were expressly preempted by the Airline Deregulation Act's federal-preemption provision. The court vacated the district court judgment for lack of subject-matter jurisdiction and later denied rehearing, concluding that the preemption provision controlled over the federal statute preserving common-law remedies.

Holdings

1. 49 U.S.C. App. § 1305 expressly preempted O'Carroll's common-law and other state-law claims because they related to the services of an air carrier.
2. The district court lacked subject matter jurisdiction over the action because the complaint alleged only state-law claims that were preempted by federal law.
3. Section 1305 controlled over § 1506 because § 1305 was enacted later and specifically addressed federal preemption; therefore, § 1506 did not preserve the asserted state-law claims.

Questions Presented

1. Whether the Federal Aviation Act expressly preempted O'Carroll's state-law claims concerning his exclusion from air transportation.
2. Whether the district court had subject matter jurisdiction over the action after the asserted state-law claims were preempted by federal law.
3. Whether 49 U.S.C. § 1506 preserved O'Carroll's state-law negligence claims despite the later-enacted express preemption provision in 49 U.S.C. App. § 1305.

Disposition

vacated