313 F. Supp. 3d 1289
N.D. Fla.2018Background
- Plaintiffs sued Med-Trans and AMGH (operator/controller of Med-Trans) under Florida law, alleging overcharging for an air-ambulance transport and asserting unjust enrichment, breach of implied-in-fact contract, and breach of the implied covenant of good faith and fair dealing.
- Defendants moved to dismiss under Rule 12(b)(6), arguing the Airline Deregulation Act (ADA) preempts Plaintiffs' state-law claims because Med-Trans is an "air carrier" with an FAA Part 135 Air Carrier Certificate.
- The court judicially noticed Med-Trans’s Part 135 Air Carrier Certificate and treated Med-Trans as an air carrier authorized to provide interstate air transportation even though the transport at issue was intrastate.
- The key legal question was whether Plaintiffs’ claims are barred by the ADA’s express preemption of state laws "related to a price, route, or service" of an air carrier or instead fall within the Wolens exception for enforcing the parties’ private undertakings.
- The court evaluated each claim (unjust enrichment, implied covenant, implied-in-fact contract) for whether it rests on state-imposed obligations (preempted) or on the parties’ self-imposed bargain (not preempted).
- Plaintiffs also sought a declaration that the ADA’s preemption clause is unconstitutional on several grounds (due process, Commerce Clause, Seventh Amendment); the court rejected these constitutional attacks.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ADA preemption applies because Med-Trans is an "air carrier" | Plaintiffs: Med-Trans isn't an "air carrier" under ADA because the transport was intrastate | Defendants: Med-Trans holds FAA Part 135 authority and may provide interstate transport, so ADA applies | Held: Med-Trans is an air carrier; ADA preemption provision applies |
| Unjust enrichment claim preempted? | Plaintiffs: Defendant retained unjust gains from overcharges; recovery is appropriate | Defendants: Unjust enrichment imposes state-created standards, not parties' bargain | Held: Claim is state-imposed (not based on parties' agreement) and is preempted; dismissed |
| Breach of implied covenant of good faith and fair dealing | Plaintiffs: Defendants breached implied covenant by charging inflated rates | Defendants: Florida law requires breach of an express contract term; claim is invalid | Held: Under Florida law claim fails absent breach of express term; dismissed |
| Implied-in-fact contract (reasonable/customary rate) — preemption risk | Plaintiffs: Parties formed implied contract; missing price term can default to reasonable rate — fits Wolens exception | Defendants: Judicial determination of reasonable rate is state rate-setting and imposes policy-based standards | Held: Court finds factual allegations distinguishable from Wolens/Wagner; requiring a court-set reasonable rate would impose state-dictated pricing and is preempted; claim dismissed |
| Constitutional challenges to ADA preemption | Plaintiffs: Preemption is arbitrary, violates due process, Commerce Clause, and Seventh Amendment | Defendants/Government: ADA is rationally related to deregulation goals; DOT remedies available; Congress acted within Commerce Clause; preemption extinguishes state causes of action but is constitutional | Held: Constitutional attacks fail; ADA preemption upheld |
Key Cases Cited
- Quiller v. Barclays Am./Credit, Inc., 727 F.2d 1067 (11th Cir. 1984) (Rule 12(b)(6) dismissal appropriate only when an affirmative defense clearly appears on the face of the complaint)
- Northwest, Inc. v. Ginsberg, 572 U.S. 273 (Supreme Court 2014) (ADA preemption bars state enforcement actions having a connection with airline rates, routes, or services)
- Morales v. Trans World Airlines, Inc., 504 U.S. 374 (Supreme Court 1992) (ADA preemption should be interpreted broadly)
- Am. Airlines, Inc. v. Wolens, 513 U.S. 219 (Supreme Court 1995) (ADA does not bar adjudication of breach-of-contract claims enforcing parties' private undertakings)
- United States v. Salerno, 481 U.S. 739 (Supreme Court 1987) (substantive due process "shocks the conscience" standard)
- Gonzales v. Raich, 545 U.S. 1 (Supreme Court 2005) (Congress may regulate local activities as part of an economic class affecting interstate commerce)
- Musson Theatrical, Inc. v. Fed. Exp. Corp., 89 F.3d 1244 (6th Cir. 1996) (DOT complaint process for unfair or deceptive practices under federal law)
- Spinelli v. Gaughan, 12 F.3d 853 (9th Cir. 1993) (Congress may preempt state causes of action; Seventh Amendment not a bar to preemption)