Delta Air Lines, Inc. and Al Perez v. Robert C. Black

Summary

The Supreme Court of Texas held that the Airline Deregulation Act preempted Robert Black’s state-law breach-of-contract and misrepresentation claims arising from Delta’s failure to provide his wife with a confirmed first-class seat. The court concluded that airline seating and boarding procedures are services within the ADA’s preemption provision and that Black’s requested remedies would improperly enlarge the parties’ contract beyond the federal regulatory scheme. The court reversed the court of appeals in part and rendered judgment that Black take nothing against Delta and Al Perez.

Holdings

1. Airline boarding procedures and seating policies relate to the services of an air carrier within the meaning of 49 U.S.C. § 41713(b)(1).
2. The ADA preempts Black's breach-of-contract claims because they concern Delta's ticketing, seating, and boarding procedures and can be adjudicated only by resort to laws or policies external to the parties' contract.
3. The ADA preempts Black's intentional and negligent misrepresentation claims because they are based on Delta's ticketing and boarding procedures and would constitute state enforcement of law relating to airline services.
4. Black could not rely on 14 C.F.R. § 250.9 because his wife was not denied boarding within the meaning of the regulation and, in any event, the offered alternative accommodations made the Blacks ineligible for denied-boarding compensation under § 250.6.

Questions Presented

1. Whether the Airline Deregulation Act of 1978 preempts state-law breach-of-contract claims based on an airline's ticketing, seating, and boarding procedures.
2. Whether the Airline Deregulation Act preempts state-law intentional and negligent misrepresentation claims based on an airline's ticketing and boarding procedures.
3. Whether the federal denied-boarding regulations, including 14 C.F.R. §§ 250.6 and 250.9, permitted Black to seek additional state-law damages for the alleged failure to provide a confirmed first-class seat.

Disposition

reversed