Monzingo v. Alaska Air Group, Inc.

Summary

The Supreme Court of Alaska held that Alaska Airlines' frequent-flyer-program contract permitted retroactive changes to award levels, including changes affecting previously accumulated miles, when reasonable notice was provided. The court concluded that the breach-of-contract claim was not preempted by the Airline Deregulation Act and affirmed summary judgment for Alaska Airlines. It reversed the attorney's-fee award to the extent it included fees incurred solely in litigating class-certification issues.

Holdings

1. The breach-of-contract claim was not preempted by the Airline Deregulation Act because it sought enforcement of Alaska Airlines' own contractual undertakings rather than the enlargement of contractual rights through external state policy.
2. Alaska Airlines' Mileage Plan reserved the right to make retroactive changes to the value of previously accumulated miles when it provided reasonable notice.
3. A named class representative should not ordinarily be liable for attorney's fees incurred solely in litigating class-certification and notice issues that do not concern the merits of the representative's individual claim.

Questions Presented

1. Whether the Airline Deregulation Act preempted Monzingo's state-law breach-of-contract claim.
2. Whether the Mileage Plan contract reserved Alaska Airlines' right, with reasonable notice, to make retroactive changes that reduced the value of previously accumulated miles.
3. Whether the parties' course of dealing supported Alaska Airlines' interpretation of the Mileage Plan.
4. Whether the superior court erred by awarding Rule 82 attorney's fees for litigation concerning class certification and notice.

Disposition

reversed_and_remanded