James W. Smith v. Comair, Incorporated Delta Airlines, Incorporated
134 F.3d 254 · Court of Appeals for the Fourth Circuit · 1998
Facts
James Smith was denied boarding on a Comair connecting flight due to identification issues, despite having boarded the initial flight without incident. He sued Comair for breach of contract, false imprisonment, and intentional infliction of emotional distress. The district court granted summary judgment, finding his claims preempted by the Airline Deregulation Act (ADA) or failing to state a claim.
Issue
Are a passenger's state law breach of contract and intentional tort claims, arising from an airline's refusal to board him due to identification requirements, preempted by the Airline Deregulation Act? If not preempted, do the tort claims for false imprisonment and intentional infliction of emotional distress state a claim under Kentucky law?
Holding
Yes, the court affirmed the district court's judgment. Smith's contract and tort claims are preempted by the ADA to the extent they complain of Comair's boarding procedures, as these procedures relate to an airline service and involve federal safety regulations. Furthermore, to the extent his tort claims rested on conduct distinct from the refusal to board, they failed to state a claim under Kentucky law.
Rule
The Airline Deregulation Act broadly preempts state law claims "related to a price, route, or service of an air carrier," including those concerning airline boarding procedures. A contract claim is only exempt from preemption if it can be adjudicated solely on the parties' self-imposed undertakings, without reference to external state laws or federal defenses. Under Kentucky law, false imprisonment requires a total deprivation of liberty, and intentional infliction of emotional distress requires conduct that is outrageous and intolerable, causing severe distress.
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