Northwest, Inc. v. Ginsberg
Holding
The Airline Deregulation Act preempts a state-law claim for breach of the implied covenant of good faith and fair dealing if it seeks to enlarge the contractual obligation that the parties voluntarily adopt.
Judgment
Reversed and remanded, 9-0, in an opinion by Samuel Alito on Apr 2, 2014.
Issue: Whether the court of appeals erred in holding, in contrast with the decisions of other circuits, that respondent”s implied covenant of good faith and fair dealing was not preempted under the Airline Deregulation Act because such claims are categorically unrelated to a price, route, or service, notwithstanding that respondent”s claim arises out of a frequent-flyer program (the precise context of”American Airlines, Inc. v. Wolens“) and manifestly enlarged the terms of the parties” undertakings, which allowed termination in Northwest”s sole discretion.
Recommended Citation: Northwest, Inc. v. Ginsberg, SCOTUSblog, https://www.scotusblog.com/cases/northwest-inc-v-ginsberg/