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Airline Alliances and Frequent Flyer Programs

Posted on 01 November 2010. Tags: Airline, Alliances, Flyer, Frequent, Programs

by Marianone

Airline Alliances and Frequent Flyer Programs

INTRODUCTION:

It is not the strongest of the species that survives, nor the most intelligent that survives. It is the one that is the most adaptable to change-Charles Darwin.

It would not be an exaggeration to state that today’s markets has undergone radical changes facilitated by advances in global information technology, economic development of third world countries, increasing interplay between various markets, political changes in various nations facilitating openness in trading practices etc. As the Oft-quoted comment these days goes, the markets have turned flatter than ever before facilitating increased movements & transactions between nations, corporates, entrepreneurs and individuals.

Increased opportunities including enlarged existing markets and emergence of new markets has been a mixed bag. Along with its obvious benefits, crippling disadvantages have also followed like its shadow. One of the industries that have had battle its effects is the airline industry. Paradoxically the increased popularity of flying as a medium of faster transportation has also been one of the factors that have brought in impediments to profitability. Since business deals are not restricted by geographical boundaries anymore and people have taken to international travel like never before-be it for business or pleasure, a spurt in demand has resulted in over-crowding within the industry-all vying for the same pie.

With most of the competitors operating from more or less similar technology platforms and offering similar services, major players within the airlines industry has had to battle commoditization of its services and offerings to its passengers. Airline and the tourism industry operate in an interconnected manner and are particularly vulnerable to global incidents like epidemics, natural disasters like earthquakes, cyclones, terrorism, volatile fuel prices etc. These have hurt the industry where it matters the most-profitability!

Every time there is a hit or threat to its financial bottom line, the marketers under pressure to perform and improve cash-flow, would struggle to create innovative marketing campaigns to rise above the communications clutter and attract the customers attention. Ironically in their urgency they end-up using the same self-destructive weapon that they would like to avoid for long term profitability-lower prices. Price-wars cannot be a part of a strategy and every time it is used, it leaves a bitter after-taste among the players within the industry.

The industry has gained maturity over the years, and airlines all over the world have been constantly revising their strategies for growth and encountering competition. This has been driven by one particular need, survival. These strategies cover cost cutting measures, better management and most importantly, strategic alliances with other airlines. Importance of these alliances may be gauged by the fact that they are guided by the bilateral air services agreement system between nations. In many cases code-sharing agreements have been made to maintain or expand coverage & these international codes-sharing has become a part of bilateral negotiations.

THE BUILDING BLOCKS:

An alliance may be understood as an agreement between two or more parties, made in order to advance common goals and to secure common interests.In matured markets, alliances makes business sense and are primarily motivated by cost reduction and improved service for the customer among other factors. Typically alliance partners are bound by a single agreement with equitable risk and opportunity share for all parties involved and are typically managed by an integrated project team.

Strategic alliances are common to any industry. Their presence is being felt quite significantly within the airline industry. Formation of alliances has been a collateral outcome of the deregulation of the airline industry in the United States in 1978. Deregulation was the single most important event that brought about radical changes within the industry. Though it took around a decade for the European countries to follow, the effects of deregulation was quick to filter-in and the airlines were finally free from governmental shackles. The airlines now could choose the routes they wanted to fly and fix the prices as they saw fit without any regulatory interventions. Thus, deregulation enabled airlines to operate based on demand-supply realities and other market realities. The freedom had its cons too-now the airlines had to fend for themselves and had to take careful steps in order to walk the path of positive financial bottomlines.

The most commonly used word these days seem to be “globalisation”. The all pervasive globalisation did not happen at one go. Deregulation of the airline industry seems to have been a precursor to it. Globalisation has set new rules and with competition coming from and for new markets, the ground realities have altered Airlines have been slowly adapting to these challenges. Maybe due to the unpredictability of the new market and its inherent vulnerability to global incidents, the industry has had to adapt itself many times over. With adaptation becoming its second nature, alliances with other operations were nothing but a survival mechanism that began many years ago. From basic code-sharing agreements, these alliances have come a long way and today involves much closer co-operation between partners. The flexibility of the format has ensured that even non-flying partners like Hotels; Credit card companies etc have been successfully integrated. No Doubt, these alliances are playing a significant role in the development of the global airline industry.

What the alliances offer a consumer is seamless worldwide travel. To that end, participating airlines have more or less integrated their flight routes, coordinating their schedules and flying from common terminals at shared hub airports so passengers connecting from one alliance partner to another can do so with minimal effort and inconvenience. With an integrated route network in place, airlines in an alliance offer fares that favor a combination of alliance partners, including round-the-world fares that showcase the alliance’s global network, permitting travelers to circumnavigate the earth exclusively using members of a single alliance. The looming presence of alliances not withstanding, the consumer still seeks his pound of flesh for his patronage from the alliance in the form of loyalty miles. In order to satisfy the consumer craving for miles, member airlines have linked their mileage programs to reward travelers for flying within the alliance network. Loyalty programs thus continue to hold sway with the Airlines Industry.

AIRLINE ALLIANCES:

In layman’s terms, an airline alliance may be defined simply “an agreement between two or more airlines to cooperate on a substantial level”. However Oum, Taylor, and Zhang (1993) offers a more comprehensive definition “a global airline network formed by a group of affiliated airlines which offer seamless services to consumers through a joint use of computer reservation systems, through fares and ticketing, automatic baggage transfer, coordinated flight schedules, code-sharing of flights, joint marketing, sharing of a frequent flyer program, etc.” (1).

International strategic alliances represent one of the strategies developed by firms to gain a competitive advantage in the global marketplace. These alliances possess the following characteristics (de la Sierra 1995)(2):

1. The two or more firms that unite to pursue a set of agreed upon goals remain independent subsequent to the formation of the alliance.

2. The partner firms share the benefits of the alliance and control over the performance of assigned tasks.

3. The partner firms contribute on a continuing basis in one or more key strategic areas (e.g., technology, products, and so forth).

Broad objectives of an airline alliance:

Many researchers have examined the various reasons that have led to the formation and sustenance of strategic alliances within the airline industry. Burton and Hanlon (1994) opine that alliances are central to formulation of business strategy. Though there are many objectives, the list below highlights a few important ones:

(1) The primary objective for international strategic alliances in the airline industry is access to foreign markets.

(2) Being a part of an alliance enables the carrier to offer a larger number of flights to a much wider choice of destinations, leading to enhanced marketing opportunities.

(3) Airlines benefit from the economies of scale resulting from an increased scope of operations.

(4) Increase traffic on the airline’s routes. Higher traffic levels allow the airline to operate larger, more efficient aircraft at higher load factors, which in turn leads to lower unit operating costs.

(5) Reduce costs through the sharing of facilities and services aircraft maintenance and ground handling.

(6) Increase market feed. Many airlines that are dominant in their home markets have entered into an alliance with an international airline to provide feed to their airlines.

(7) The linking of flights within computer reservation systems allows ticketing and seat assignments for connecting flights to be completed at the point of origin, which benefits the connecting passenger.

(8) Other objectives behind the formation of global alliances between airlines include: the projected growth of international travel versus domestic travel, intensified fare competition, gate/slot constraints, hub congestion, market withdrawal costs, aircraft systems development, human resource development and a desire to match strengths and weaknesses.

International strategic alliances represent one of the strategies developed by firms to gain a competitive advantage in the global marketplace. Strategic alliances between airline partners have become a popular business strategy.

Alliance benefits in a nutshell may be summarised as:

(1) Ability to offer a wide range of airline partners.

(2) Better lounge/airport facilities.

(3) More destinations.

(4) Ability to offer round fares/circle fares.

(5) Greater ability to reward passengers.

(6) Faster Mileage accrual.

(7) Larger number of reward destinations.

(8) Better up sell opportunities.

(9) Cost-effective monolithic customer retention/acquisition strategies.

(10) Access to extended passenger database.

(11) Large and international partner portfolio.

(12) Invest in sophisticated campaign management tools.

(13) Joint development of easy to use services for passengers.

(14) Dedicated professional management for meeting alliance objectives.

(15) Increased cost-efficiencies.

(16) Increased aircraft utilization.

(17) Globalised airline operations.

(18) Simplified mileage accounting.

FFP is the most visible joint product of the alliance on the customers’ side. Consumer loyalty programs such as frequent flyer programs (FFPs) have proven their ability to alter the intensity of price competition between firms. The increasing marginal benefits that are built into the reward schedules of FFPs give consumers an incentive to concentrate their flying with a single carrier, rather than choose carriers on a flight-by-flight basis. Indeed, both economists and policy analysts have suggested that FFPs might enhance the market power of airlines, in particular, of dominant carriers at hub airports. The FFP points available on a flight are clearly a characteristic that consumers consider in deciding which airline product to purchase. Consumers value frequent flyer points because accrued points give them dual benefit- attractive rewards and the benefits of tier status. Thus, the value of frequent flyer points is derived from the value of the rewards for which they can be redeemed and the probability that a consumer will accumulate enough points to redeem a reward and achieve tier status.

Even within airline alliances, FFPs remain a key component of global strategy. It is interesting to note that the very first airline alliance was built around a FFP. The defunct Swissair owned the “Qualiflyer” FFP and took majority stakes in various airlines which were linked with Qualiflyer. The three existing Global Alliances (Star Alliance, SkyTeam and One World) aim to provide many benefits to their clients, including reciprocal mileage accrual and award tickets. Thanks to huge ICT investments, they introduced standard procedures for data exchange, miles and award settlement, recognition of higher tiers, web booking tools, etc.

WORLDWIDE AIRLINE ALLIANCES:

The three largest alliances that are centered on passenger airlines are the Star Alliance, SkyTeam and Oneworld. Alliances also have also been formed between cargo airlines, such as that of WOW Alliance, SkyTeam Cargo and ANA/UPS Alliance. Alliances provide a network of connectivity and convenience for international passengers and international packages. Various aspects of airline alliances have been discussed in detail above.

Loyalty programs are prime pivots that determine the success of airline alliances. Since there are multiple airlines that are part of an alliance thus bringing with them multiple programs with varied and complex rules, alliances typically offers a single alternative loyalty program that is also umblically integrated with the primary loyalty programme belonging to the “home” airline. In order to protect and maintain the primacy of individual airline FFPs most alliances have the rule that the passenger has to take a minimum no. of flights a passenger before being eligible for an alliance loyalty programme. The alliance loyalty programme also has its own set of tiers. The one world alliance tiers are branded as Emerald, Sapphire and Ruby. By creating an alliance FFP programme, a single data pipeline is created from varied sources that are many and also varied, giving the alliance management the opportunity to process large amounts of heterogeneous data.

FACTS AND NUMBERS-A SNAPSHOT

STAR ALLIANCE

Year of Formation

1997

Daily Departures

16,500

Countries Served

159

Lounges

805

Annual Passengers

499.90 (m)

Number of Employees

393,559

Fleet

3,325

Available Seat Kilometers

1280.5 (bil)**

Global Passenger Shares

454.4 (mil)**

Revenue Passenger Kilometers

980.8 (bil)**

Operating Revenue Shares

127.2 (bil)**

Frequent Flyer Members

SKYTEAM

Year of Formation

2000

Daily Departures

16,787

Countries Served

169

Lounges

447

Annual Passengers

462 (m)

Number of Employees

356,998

Fleet

2469 (+1,255 from related carriers)

Available Seat Kilometers

1042.9 (bil)**

Global Passenger Shares

375.6 (mil)**

Revenue Passenger Kilometers

818.9 (bil)**

Operating Revenue Shares

97.9 (bil)**

Frequent Flyer Members

152 (mil)

ONEWORLD

Year of Formation

1999

Daily Departures

8,951

Countries Served

134

Lounges

531

Annual Passengers

318.6 (m)

Number of Employees

275,991

Fleet

2,228

Available Seat Kilometers

891.1 (bil)**

Global Passenger Shares

285.5**

Revenue Passenger Kilometers

684.8 (bil)**

Operating Revenue Shares

86.8 (bil)**

Frequent Flyer Members

** Source: IATA WATS published 2007. (3)

These numbers indicate that alliances are a significant factor within the airline industry, and that the success of these alliances will determine the success of global airline markets. Not entirely, but a world class loyalty program is a big contributor to business success.

STAR ALLIANCE –SAMPLE UNIFIED LOYALTY PROGRAM:

Star Alliance has two premium levels, Silver and Gold, based on a customer’s tier status in a member carrier’s frequent flyer program. Each of the member and regional airlines recognizes Star Silver/Gold status, with a few exceptions (mainly pertaining to airport lounge access). The statuses have no specific requirements of their own; membership is based solely on the frequent flyer programs of individual member airlines. Many member airlines also have an additional premium status beyond Gold which is not recognised across Star Alliance.

Star Alliance Silver

Star Alliance Silver status is awarded to customers who have reached a premium level of a member carrier’s frequent flyer program.

Benefits of Star Alliance Silver membership:

Priority reservations wait listing Priority airport stand-by

Some airlines also offer the following to Silver members:

Priority boarding Priority airport check-in Priority baggage handling Preferred seating Additional checked luggage allowance Airport lounge access Star Alliance Gold

Star Alliance Gold status is awarded to customers who have reached a high level of a member airline’s frequent flyer program.

Benefits of Star Alliance Gold membership:

Priority reservations wait listing Priority airport stand-by Priority boarding Priority airport check-in Priority baggage handling Additional checked luggage allowance of 20kg (or one extra piece where the piece concept applies) Airport lounge access to designated Star Alliance Gold lounges on the day and at the place of departure, on presentation of a valid Star Alliance boarding pass.

Some airlines also offer the following to Gold members:

Preferred seating (exit seat, or even on a special section on the plane on some carriers, which provides more leg room) Guaranteed seating on fully booked flights (subject to the booking class code and notice period) Free upgrade (in the form of voucher/certificate or automatic upgrade upon check-in)

CONCLUSION

Close relationships between airlines are nothing new. Despite the cut-throat competition that exists among individual airlines, the industry operates within a highly cooperative framework. Airlines routinely sell and accept each other’s tickets, transfer luggage between each other’s flights and offer other conveniences. It always seems logical for non-competitive airlines to take that kind of cooperation to the next level, sharing codes, creating joint fares and participating in each other’s frequent flyer programs. Airline alliances were just another step in that direction. International strategic alliances are an important strategy in the development of global airline markets. A study estimated that 66 percent or two out of every three passengers fly with an alliance carrier which makes it apparent that in the aviation industry today, alliances play a critical role. While there were many doubters regarding the longevity of global airline alliances, it has more or less been established as a fact of today’s travel life. Today’s Airline world is consolidating around three major alliances- Star Alliance, Skyteam and Oneworld.

Loyalty Programs have been a vital marketing tool for the airline industry that has enabled them to constantly add value and de-commoditise their services and offerings. it is interesting to note that joint FFP plans seems to be the most common marketing activity entered into by alliance partners in attempting to build a seamless network for the traveler. Frequent flier programs predominantly developed as a tool to regain customer loyalty and reward frequent & high yield passengers continue to have substantial capability to impact the travel Industry. The successes that the alliances have posted have been due to various reasons including seamless travel, better usage of amenities at airports etc, but one of the vital reasons remain that code-sharing effectively merges the members Frequent flyer miles and programs letting them use built-up mileage from one carrier on several others.

According to Harvard Business Review, A 2% increase in customer retention can have the same financial impact as a 10 percent reduction in operating costs. Joining an alliance is proving to be a cost effective way of increasing both frequencies and network pushing more and more airlines to be a part of alliances. This has resulted in alliances increasing their joint market-share & thus being a catalyst for change in the aviation industry.

In an uncertain conjuncture, airline alliances are becoming more influential due to the numerous synergies that exist in the aviation sector. Each of the big alliances today offers an integrated worldwide network, harmonized customer benefits and coordinated loyalty programmes. Here we are forced to concede that Airline alliances are here to stay and loyalty programs will continue to play their vital role in their success.

REFERENCES:

(1) Oum, Tae Hoon Taylor, Allison J. Zhang, Anming (1993), “Strategic Airline Policy in the Globalizing Airline Networks, “Transportation Journal, (Spring), 14-30.

(2) De la Sierra, M. Cauley (1995), Managing Global Alliances: Key Steps for Successful Collaboration. Workingham, England: Addison-Wesley Publishing.

(3) http://www.staralliance.com/int/press/media_library/presentations/200503_ADP_MoU_Press_Briefing.pdf

GLOSSARY:

(1) Available Seat Kilometers: One seat transported one kilometer; the most common measure of airline seating capacity or supply. For example, an aircraft with 100 passenger seats, flown a distance of 100 kilometers, produces 10,000 ASKs. Sometimes ALSO measured in available seat miles (ASMs).

(2) Operating Revenue: Revenues from the performance of air transportation and related incidental services, including (1) transportation revenues from the carriage of all classes of traffic in scheduled and nonscheduled services, and (2) non-transportation revenues consisting of federal subsidies (where applicable) and services related to air transportation.

Endnote: The author would like your feedback-both bouquets & brickbats. Write to me- sanjai.velayudhan@gmail.com.

A behavioural trainer by education and a loyalty specialist by profession, Sanjai has PG qualifications in Training and Performance management from CLMS, University of Leicester.

Sanjai is a compulsive writer and has recently chosen articlebase to put his thoughts together. He is a loyalty specialist and works with ITC Infotech India Limited, Bangalore. Apart from creating innovative loyalty solutions, we also writes whitepapers/articles on loyalty programmes and the psychology behind it. To read some his papers, please visit:

http://www.itcinfotech.com/Loyalty-Solutions/Home.html.

you can watch his talk on loyalty -www.24framesdigital.com/winningedge/260608/ or write to him -sanjai.velayudhan@itcinfotech.com

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Cheapest Airline Tickets of My Travel Plans

Posted on 30 September 2010. Tags: Airline, Cheapest, plans, Tickets, TRAVEL

by smemon87

Cheapest Airline Tickets of My Travel Plans

I am looking for the cheapest airline tickets first when I start this part of my travel plans. That does not always mean that I buy the cheapest airline tickets that I find. Not at all! As I have pointing out in other topics the other factors associated with airline flights may end up being more important to my for this particular flight than just the cost of the flight. If the cheapest airline tickets I find turn out to meet all my other requirements then they are the ones that I buy and I have fulfilled my goal of finding the best deals available.

An international airline ticket has some special concerns especially since 9/11. The way the individual airline handles the passport and other port of entry requirements may be the deciding factors in your choice as to which airline you want to use.

Many of these factors you will only know if you have flown the airline before. You may want to ask other people you know about their experiences with the airline you a re considering before making your finial choice.

An international airline ticket can be very expensive but can also be the best deal in the airline market. TravelZoo.com is an excellent web site to keep in mind for the cheapest airline tickets and travel deals in general. They offer a FREE Subscription to the Top 20® travel deals and this is a worthy place to check.

Compare airfares with SideStep, the traveler’s search engine, and check out flight deals from over 150 travel sites and 600 airlines with one click. Find cheap airfares, discount hotels, cruise vacations, car rentals, and vacation packages to popular travel destinations worldwide. Also, check out our interactive travel guides for suggestions on travel information.

Sometimes I want to fly first class and then the search for the cheapest airline tickets can mean some real money! I have found the biggest disparity between airline ticket prices when flying first class. Airlines sometimes change prices for the same trip several times each day. In particular if you’re buying your ticket straightforwardly from the carrier, ask if the declared airfare is the least expensive.

When you decide to use the Internet to compare prices for the cheapest airline tickets, compare ticket prices on many web sites to make sure you are actually getting the cheapest airfare. Compare airfares with SideStep, the traveler’s search engine, and check out flight deals from over 150 travel sites and 600 airlines with one click. Find cheap airfares, discount hotels, cruise vacations, car rentals, and vacation packages to popular travel destinations worldwide. Also, check out our interactive travel guides for suggestions on travel information.

Usually, we find that the longer the flight, the bigger the savings. This is generally true but not always. So, take your time and compare prices. An international airline ticket can be very expensive but can also be the best deal in the airline market. TravelZoo.com is an excellent web site to keep in mind for the cheapest airline tickets and travel deals in general. They offer a FREE Subscription to the Top 20 travel deals and this is a worthy place to check.

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Airline Miles Credit Cards – Survey & Comparison

Posted on 17 August 2010. Tags: Airline, Cards, Comparison, Credit, Miles, Survey

by caribb

Airline Miles Credit Cards – Survey & Comparison

At one time, there were not many airline credit cards available for you to choose from. The first of the airline miles credit cards was the Citi AAdvantage MasterCard, which is still available today. Though this card had plenty to offer, it wasn’t necessarily the best airline credit card for everyone.

The Evolution of Airline Credit Cards

Over time, airline miles credit cards began to evolve. Soon after the Citi AAdvantage MasterCard hit the market, the United Airlines Mileage Plus card was offered by through a partnership with United Airlines. Shortly after, Continental Airlines followed suit with the Continental Airlines World MasterCard. These leaders in the airline miles credit card industry started what has become a widespread credit card option for frequent travelers.

Partnering with Airlines

The partnerships formed between credit card companies and airlines put a new face on airline credit cards. Today, there are just as many airline credit cards to choose from as there are airlines. The majority of these airline credit cards pretty much the same, though the subtle nuances can vary from card to card. With all of these cards, the miles you earn are good for use with just the airline named on the card. The only exception to this is if the airline has sister companies. In this case, the miles may be good with the sister airlines as well.

Generic Airline Credit Cards

In addition to the vast number of airline credit cards that are formed in partnership with airlines, there are many generic credit cards. In this case, the word “generic” doesn’t stand for off brand or low quality. Rather, these cards allow you to earn airline miles that you can use with any airline of your choice. Usually, these cards work by assigning each airline mile a monetary value, usually 1 or 2 cents per mile. You can then use these miles to purchase a ticket through the credit card company that the company has acquired from the airline at a discounted price.

With generic airline credit cards, you are provided far more freedom in deciding which airline to use. This allows you to select the airline that is running a flight at the time and location that is best for you. It also allows you to take advantage of market fluctuations in ticket prices from one airline to the next.

Additional Perks

In addition to the number of miles it takes to earn free travel with airline credit cards, you should consider the additional perks offered. For example, so airline credit cards only provide special discounts for air travel. On the other hand, some cards allow you to redeem your points for other travel related necessities, such as car rentals, cruises, hotel stays, and vacation packages.

You should also pay attention to the special incentives offered by airline miles credit cards. Some allow you to earn bonus miles through certain purchases. For example, you might be able to earn bonus miles with a credit card that has partnered with a specific airline if you make purchases from that airline on the credit card.

In addition to incentives, some airline credit cards provide sign up bonuses. It is fairly common for an airline credit card to offer 5,000 bonus miles after using the card for the first time. The Gold Delta Skymiles Credit Card and American Express Credit Cards offer 10,000 bonus miles. Of course, you need to look out for how many miles it takes to earn a free ticket. The average number of miles needed with airline credit cards is 25,000, but you should always read all of the fine print first before making a decision.

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History of Airline Credit Cards

Posted on 08 August 2010. Tags: Airline, Cards, Credit, History

by express000

History of Airline Credit Cards

Airline credit cards have not been around for as long as you may think. In fact, they are a fairly new option available to credit cardholders. Nonetheless, airline credit cards have quickly gained in popularity and can be found partnered with every major airline.

The First Airline Credit Card

The first airline credit card to be offered to consumers was the City AAdvantage MasterCard. When it came out, the card allowed consumers to earn miles with every purchase made. These miles could then be redeemed for free air travel through a variety of airlines. This card remains one of the major players in the airline credit card industry. Today, you can redeem your airline miles at over 25 different airlines. In addition, you can redeem miles for discounts at numerous hotels and car rental companies.

Airlines Follow Suit

Realizing what a great idea airline miles credit cards was, airlines started following suit and partnering with credit card companies to create their own airline credit card. The United Airlines Plus card was next. This card was the first airline credit card to be specific to an airline. Although the card did not offer the flexibility of receiving discounted tickets with numerous airlines, those who frequently traveled on United Airlines enthusiastically embraced this United Airlines credit card.

Not to be outdone, Continental Airlines unveiled its airline credit card, the Continental Airlines World MasterCard, shortly after United Airlines. Both airlines still offer their own airline miles credit cards, but provide their own special incentives to set them apart from the competition. Today, the United Airlines Plus Signature Visa Credit Card offers 17,500 bonus miles after the first purchase with the card, a certificate for a free one-way 1,000 mile one-class upgrade, and a certificate for discount travel. The Continental Airlines World MasterCard offers 15,000 OnePass bonus miles after completing your first purchase. In addition, you can earn double OnePass miles with purchases made at Continental Airlines and with partner merchants and a 5% discount on Continental Fares purchased at their website using the card.

Airline Miles Credit Cards Today

Today, airline credit cards are in abundance. Every major airline has partnered with a credit card company in order to bring their own airline credit card to the consumer. In addition, competition to gain and to retain flying customers is fierce. Therefore, airline credit cards offer a number of incentives, bonuses, and special deals to entice customers into acquiring their credit card.

In addition, the number of “generic” airline miles credit cards is on the rise. It is not unheard of for an airline credit card to allow the consumer to choose from over 200 different airlines when redeeming earned miles. Many of these airline credit cards also offer other discount options, such as hotel, car rental, and vacation package discounts that can be purchased with earned miles.

The Future of Airline Credit Cards

With the competition being so strong when it comes to airline customers and credit card customers, the future of airline credit cards looks bright for consumers. In all likelihood, the number of incentives and bonuses will continue to rise in order to draw in new cardholders. A trend that is currently starting to develop are special low APRs and annual fees. Traditionally, airline miles credit cards have had annual fees and high APRs when compared to credit cards without rewards programs. While this remains true, more and more airline credit cards are starting to offer competitive APRs and waiving annual fees in an attempt to attract more customers.

One thing is for certain: airline miles credit cards will continue to be popular among consumers, particularly for those that can pay off their balance in full at the end of each month and take full advantage of the special rewards.

For more on airline credit cards, Robert Alan recommends that you visit CreditCardAssist.com.

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Preemption of State Law Intentional Tort Actions Under the Airline Deregulation Act of 1978

Posted on 10 July 2010. Tags: 1978, Actions, Airline, Deregulation, Intentional, Preemption, State, Tort, Under

by superciliousness

Preemption of State Law Intentional Tort Actions Under the Airline Deregulation Act of 1978

After years of tight government control over the airline industry, Congress chose to pursue a policy of economic deregulation, enacting the Airline Deregulation Act of 1978 (ADA). Areas formerly controlled by the federal government, such as the awarding of routes, the entry of new air carriers, and the setting of fares, were left to the airlines and the free market to determine. Congress, concerned that States might attempt to circumvent federal airline deregulation through their own state enforcement actions, included an express preemption clause in the ADA, which bars States from enforcing laws ârelated to a price, route, or service of an air carrier.â This apparently innocuous provision continues to cause confusion and divide courts over exactly what causes of action are preempted by the ADA.

Top-ranked Chicago personal injury attorney, Matthew A. Passen, examines one class of state-law based actions, intentional tort claims, and considers whether such actions are sufficiently ârelated toâ an airline âserviceâ for preemption under the ADA. For example, can a passenger who was refused boarding on a commercial airline and strapped to an immobile chair in the waiting area sue the airline for false imprisonment? Can a passenger detained by airline employees upon landing of an aircraft, wrongfully accused of stealing another passengerâs ring, and arrested by police, seek recourse against the airline for false arrest, intentional infliction of emotional distress or slander? Can an airline racially discriminate against a passenger or airline employee with impunity?

As the following discussion reveals, the answer to these questions often depends entirely on how broad or narrow courts interpret the ADAâs statutory phrase, ârelated to a . . . service of an air carrier.â If a narrow reading is adopted, plaintiffs will have their day in court. If, on the other hand, a court interprets the preemption provision broadly, airlines will essentially receive immunity from state-law intentional tort actions.

Often, the best answer to such questions of statutory interpretation is found by reconsidering the purpose of the underlying statute containing the preemption provision. Here, the purpose of the ADA is straightforward: economic deregulation of the airline industry.

BRIEF HISTORY OF THE ADAâs PREEMPTION CLAUSE

Prior to 1978, the federal government heavily regulated the airline industry.1 Beginning with the Federal Aviation Act (FAA) of 1958,2 Congress created a regulatory organization, known as the Civil Aeronautics Board (CAB), to serve three main functions: award routes to airlines, control the entry of air carriers into new markets, and regulate fares for consumers.3 Still, Congress preserved state common law actions against airlines by including a âsaving clause,â which provided: âNothing contained in this chapter shall in any way abridge or alter the remedies now existing at common law or by statute, but the provisions of this chapter are in addition to such remedies.â4

In 1978, however, Congress changed courses with respect to airline regulation, determining that âmaximum reliance on competitive market forces would best further âefficiency, innovation, and low pricesâ as well as âvariety [and] quality . . . of air transportation services.â5 Accordingly, Congress enacted the Airline Deregulation Act of 1978 (ADA),6 which gradually ended economic regulation of the airline industry in a series of steps over the years, including the elimination of the CAB.7

The ADA, unlike its predecessor, contained express federal preemption clause to ensure that âStates would not undo federal deregulation with regulation of their own.â8 The ADAâs preemption clause states:

Except as provided in this subsection, a State, political subdivision of a State, or political authority of at least 2 States may not enact or enforce any law, regulation, or other provision having the force and effect of law related to a price, route, or service of any air carrier that may provide air transportation under this subpart.9

This preemption standard, while simply stated, has proven far more difficult to apply than Congress could have anticipated.

One source of confusion is Congressâ retention of the âsaving clause,â which provides that â[a] remedy under this part is in addition to any other remedies provided by law.â 10 Some courts have found Congress preserved this clause in order to protect the statesâ ability to control non-economic matters involving airlines within their respective borders.11 Still, the Supreme Court has referred to the saving clause as âa relic of the pre-ADA/no pre-emption regime,â without power to supersede the specific substantive preemption provision of the ADA. 12

The greatest source of confusion surrounding the ADAâs preemption clause concerns the ambiguous language of the statute itself. In particular, courts have struggled to advance a coherent framework for what types of causes of action are ârelated to a price, route, or serviceâ for preemption under the ADA. Congress neither defined the terms nor specified what types of state action are preempted, and the Supreme Court has not drawn any distinct preemption lines.13 Consequently, lower courts have been left to apply their own, often conflicting, interpretations of the ADAâs preemption clause. Regardless of statutory interpretation, courts remain guided by fundamental principles of preemption doctrine.

BRIEF INTRODUCTION TO PREEMPTION DOCTRINE

The foundation for federal preemption of state law is based on the Supremacy Clause of Article VI of the Constitution, which provides: âThis Constitution and the laws of the United States . . . shall be the supreme law of the land . . . anything in the Constitution or laws of any State to the contrary notwithstanding.â14 As a general rule, federal law preempts state law in three situations:15 (1) Express preemption: where Congress has explicitly preempted state law;16 (2) Field preemption: where Congressional intent to preempt may be inferred generally from the pervasiveness of a federal regulatory scheme in a particular area;17 and (3) Conflict preemption: where state law conflicts with federal law or interferes with the achievement of congressional objectives.18

Where Congress has included an express preemption clause in a statute, courts âtypically do not consider the issue of implied pre-emption,â and instead simply âdetermine whether the state law in question falls within the scope of the statute expressly promulgated by Congress.â19 In other words, according to the Supreme Court:

When Congress has considered the issue of pre-emption and has included in the enacted legislation a provision explicitly addressing that issue . . . âthere is no need to infer congressional intent to pre-empt state laws from the substantive provisionsâ of the legislation. Such reasoning is a variant of the familiar principle of expression unius est exclusio alterius: Congressâ enactment of a provision defining the pre-emptive reach of a statute implies that matters beyond that reach are not pre-empted.20

Because Congress included an express preemption clause in the ADA, courts look to the specific statutory language in order to determine whether a particular state action is preempted. Unfortunately, the literal text of the ADAâs preemption clause is ambiguous; and the Supreme Court has not resolved the uncertainty.

SUPREME COURT INTERPRETATION OF

THE ADAâs PREEMPTION CLAUSE

The United States Supreme Court has interpreted the ADAâs preemption provision only twice since 1978. In Morales v. Trans World Airlines, Inc.,21 the Court decided whether the ADA preempts States from regulating deceptive airline fare advertisements through enforcement of state consumer protection statutes.22 The Court held such actions were indeed preempted by the ADA.23

In reaching its decision, the Court focused on the statutory phrase ârelated toâ in the ADAâs preemption provision. First, the Court looked to Blackâs Law Dictionary for guidance, concluding that âthe words thus express a broad pre-emptive purpose.â24

Second, the Court examined the similarly worded preemption provision of the Employee Retirement Income Security Act of 1974 (ERISA),25 which the Court had previously interpreted as having a âbroad scope.â26 Therefore, the Court held: âSince the relevant language of the ADA is identical [to the ERISA preemption clause], we think it appropriate to adopt the same standard here: State enforcement actions having a connection with or reference to airline ârates, routes, or servicesâ are pre-emptedâ by the ADA.27 Although the Court in Morales declined to define with particularity the circumstances under which a state law ârelates toâ airline services, it held the state consumer protection guidelines at issue were sufficiently ârelated toâ airline âprice[s]â because enforcement of such guidelines would compel or restrict airline price advertising.28

Notably, however, the Court recognized there are limits to the scope of the ADAâs preemption clause.29 Specifically, the Court explained that state action affecting the airlines in âtoo tenuous, remote, or peripheral a mannerâ will not be preempted by the ADA.30 The Court declined to expand on this notion, instead stating, â[t]he present litigation plainly does not present a borderline question, and we express no views about where it would be appropriate to draw the line.â31

In 1995, the Supreme Court revisited the ADAâs preemption clause in American Airlines, Inc. v. Wolens.32 Here, the plaintiffs brought claims against American Airlines for breach of contract and for violations of the Illinois Consumer Fraud Act following the airlineâs unilateral devaluation of frequent flyer mileage credits earned by the plaintiffs.33 Rather than focusing on the ârelated toâ language of the ADAâs preemption clause, the Court examined the phrase âenact or enforce any lawâ in the provision.34

First, in accord with Morales, the Court held that the plaintiffsâ claims based on the Illinois Consumer Fraud Act were preempted by the ADA.35 The purpose of the Illinois statute, according to the Court, was âto guide and police the marketing practices of the airlines; the Act does not simply give effect to bargains offered by the airlines and accepted by airline customers.â36 Therefore, because the plaintiffs sought to âenforce [a] lawâ regulating âthe selection and design of marketing mechanisms appropriate to the furnishing of air transportation services,â the plaintiffsâ claims under the Consumer Fraud Act were preempted.37

Second, the Court carved out an exception to ADA preemption for the plaintiffsâ breach of contract claim. The Court explained: âWe do not read the ADAâs preemption clause, however, to shelter airlines from suits alleging no violation of state-imposed obligations, but seeking recovery solely for the airlineâs alleged breach of its own, self-imposed undertakings.â38 Because the plaintiffsâ breach of contract claim (based on Americanâs modification of its frequent flyer program) sought to enforce the terms of a voluntary undertaking by the airlines, and did not seek to âenforce any law,â the claim was not preempted by the ADA.39

COURTS OF APPEALSâ CONFLICTING DEFINITION OF âSERVICEâ

Although the Supreme Court interpreted the ârelated toâ phrase in Morales, and the âenact or enforce any lawâ language in Wolens, the Court has not defined the term âserviceâ of an airline, as it is used in the ADAâs preemption clause. Instead, the United States Courts of Appeals have been left to define the term, resulting in conflicting approaches.

In Charas v. Trans World Airlines, Inc., the Ninth Circuit adopted a relatively narrow definition of âservice.â40 Because the term âserviceâ is inherently ambiguous, the court looked to the purpose behind the ADA, which Congress enacted to protect âthe economic deregulation of the airlines and the forces of competition within the airline industry.â41 As such, only state laws that interfere with economic deregulation and the forces of competition within the airline industry should be preempted.42 Conversely, ADA preemption should not âdisplace state tort law in actions that do not affect deregulation in more than a âperipheral manner.ââ43

With these principles in mind, the Ninth Circuit defined âservice,â as referring to âthe prices, schedules, origins and destinations of the point-to-point transportation of passengers, cargo, or mail.â44 This definition includes âsuch things as the frequency and scheduling of transportation, and to the selection of markets to or from which transportation is provided.â45 This definition of âserviceâ does not, however, encompass things such as âthe pushing of beverage carts, keeping the aisles clear of stumbling blocks, the safe handling and storage of luggage, assistance to passengers in need, or like functions,â which the court found only peripherally affect airline deregulation or competition.46 Any broader a definition, according to the court, âeffectively would result in the pre-emption of virtually everything an airline does. It seems clear to us that that is not what Congress intended.â47 This approach to ADA preemption has been followed by the Third Circuit.48

In contrast, the Fifth Circuit adopted a much broader definition of âservice.â49 In Hodges v. Delta Airlines, Inc., a female passenger was injured when another passenger opened an overhead compartment and dislodged a case of rum. She brought a state law personal injury claim against Delta Airlines based on alleged negligent operation of the aircraft.50 In order to determine whether the plaintiffâs claim was preempted by the ADA, the Fifth Circuit adopted the following definition of âserviceâ:

âServicesâ generally represent a bargained-for or anticipated provision of labor from one party to another . . . Elements of the air carrier service bargain include items such as ticketing, boarding procedures, provisions of food and drink, and baggage handling, in addition to the transportation itself. These matters are all appurtenant and necessarily included with the contract of carriage between the passenger or shipper and the airline. It is these [contractual] features of air transportation that we believe Congress intended to de-regulate as âservicesâ and broadly to protect from state regulation.51

This definition of âserviceâ is clearly far broader than the Ninth Circuitâs definition in Charas.

Still, the Fifth Circuit held the plaintiffâs claims were not preempted by the ADA. The court distinguished between claims related to the âoperation and maintenance of the aircraft,â and claims related to airline âservices,â holding that claims falling in the former category are not preempted by the ADA.52 With respect to the plaintiffâs claims, the court explained: âOne uses the overhead luggage racks or the food and beverages provided in aircraft operation just as one uses the cigarette lighter or built-in cooler compartment in an automobile, and all these devices are available to support the general purpose of navigation.â53 The court rejected Deltaâs arguments that the plaintiffâs injuries arose out of the âserviceâ of baggage handling and boarding.54 Instead, the court found: âWhether certain luggage may be placed in overhead bins and whether the flight attendants properly monitor compliance with overhead rack regulations are matters that pertain to the safe operation of a flight.â55

Thus, while the Fifth Circuit adopted a broad definition of âservice,â it added another layer of confusion with an almost untenable distinction between âserviceâ and âoperation and maintenance.â 56 Nevertheless, at least three other Circuit Courts of Appeals have adopted the Hodges courtâs definition of âservice.â57

SUPREME COURT DECLINES TO DEFINE âSERVICEâ

In late 2000, the Supreme Court declined the opportunity to resolve the conflict concerning the appropriate definition of âserviceâ within the meaning of the ADAâs preemption clause.58 Earlier that year, in Duncan v. Northwest Airlines, Inc., the Ninth Circuit held that a class-action lawsuit challenging Northwestâs smoking policy was not preempted by the ADA.59 Relying on its earlier narrow definition of âserviceâ in Charas, the Ninth Circuit held that allowing smoking on Northwest flights does not constitute a âserviceâ because such decision does not deal with âthe frequency and scheduling of transportation, [or] the selection of markets to or from which transportation is provided.â60 Northwest appealed the Ninth Circuitâs decision, and the Supreme Court denied the petition for a writ of certiorari.61

Justice OâConnor, joined by Chief Justice Rehnquist and Justice Thomas, dissented to the Courtâs denial of certiorari. In her dissent, she notes how the Courts of Appeals have âtaken directly conflicting positions on this question of statutory interpretation.â62 Given these contradictory interpretations, the dissenting Justices would have granted certiorari in order to âprovide needed certainty to airline companies.â63

APPLICATION OF THE ADA PREEMPTION CLAUSE

TO STATE-LAW INTENTIONAL TORT CLAIMS

Also in her dissent to the Courtâs denial of certiorari in Duncan, Justice OâConnor suggests that while the underlying case involved a state law personal injury claim based on an airlineâs smoking policy, âthe legal principle at stake,â namely, the correct definition of âserviceâ within the meaning of the ADAâs preemption clause, âhas ramifications for a host of other tort actions against airline,â including âfalse imprisonment,â âintentional infliction of emotional distress,â and âdefamation.â64 This section examines how courts have analyzed and should analyze these types of actions. Such cases often include state law discrimination claims.

DISCRIMINATION CLAIMS

The United States Supreme Court has not decided whether actions against airlines alleging state discrimination violations are preempted by the ADA.65 For lower courts examining this issue, the preemption outcome largely depends on the courtâs definition of âservice.â

A. Employment Discrimination Actions

Generally, discrimination suits brought by former airline employees bear âtoo tenuous, remote or peripheralâ a relation to airline rates or services for preemption under the ADA, regardless of the courtâs definition of âservice.â66 Courts refusing to preempt such actions stress the purpose of the ADA, which âwas concerned with the statesâ attempt to regulate airline fares, routes and services, not employment practices.â 67

For example, in the racial discrimination context, courts generally agree that neither air safety nor market efficiency is appreciably diminished by the operation of state laws forbidding racial discrimination.68 As the Second Circuit explained in Abdu-Brisson: âUnlike the regulation of marketing practices at issue in Morales or the regulation of frequent flyer programs at issue in [Wolens], whether an airline discriminates on the bases of age (or race or sex) has little or nothing to do with competition or efficiency.â69

In other contexts, however, enforcement of state discrimination laws may appreciably ârelate toâ airline âservices,â warranting preemption by the ADA. For instance, in 1996, the Michigan Court of Appeals held that state law weight discrimination claims brought by a baggage handler who was terminated for failure to comply with the airlineâs height and weight standards were preempted by the ADA.70 Applying the Supreme Courtâs broad interpretation of the phrase ârelated toâ in Morales, the Michigan Court of Appeals held the plaintiffâs discrimination claims “related to” the âservices of an air carrier,â and were preempted accordingly.71 In this case, as well as in other disability discrimination actions where the state law arguably ârelates toâ airline âservice,â the scope attached to these statutory terms ultimately determines the preemption outcome.

B. Passenger Discrimination Actions

Cases addressing the scope of ADA preemption in discrimination actions brought by airline passengers provide a less coherent body of case law.72 Ultimately, whether or not a discrimination claim is preempted depends on the courtâs definition of âservice.â

Generally, courts have found such claims entirely unrelated to the performance of airline services, and therefore outside the scope of ADA preemption.73 For example, in Doricent v. American Airlines, Inc., a male passenger alleged that prior to his flightâs departure from Haiti, American Airlines employees referred to him using racial epithets, threatened to remove him from the plane, and physically assaulted him.74 The court held the plaintiffâs state law race discrimination claims did not ârelate toâ airline âservicesâ under the Supreme Courtâs precedent in Morales.75 While the airline employeesâ behavior might âarguably constitute âservicesââpoor services, to be sure,â the court found this behavior had ânothing whatsoever to do with any legitimate or quasi-legitimate industry-wide practice of affording airline service.â76

Still, in other contexts, discrimination claims may have some legitimate bearing on an airlineâs ability to render safe and efficient âservice.â77 In such cases, even those involving alleged race discrimination, the plaintiffâs discrimination claims might be preempted by the ADA.

For instance, in Huggar v. Northwest Airlines, Inc., the United States District Court for the Northern District of Illinois held that an airline passengerâs race discrimination claims against Northwest were preempted by the ADA.78 The plaintiff, a 21-year-old black male was removed from a Northwest flight after removing another passengerâs luggage from an overhead bin and throwing it on the floor, threatening to physically assault the passenger, and claiming he could âbuyâ the passenger.79 The plaintiffâs ten-count claim against Northwest alleged that his ejection from the flight was racially motivated, and included a claim for a violation of the Illinois Human Rights Act.80

In determining whether the plaintiffâs state law race discrimination claims related to Northwestâs âserviceâ of providing airline transportation, the court employed the following analysis: âthe critical inquiry is [sic] the underlying nature of the actions taken, not the manner in which they were accomplished. Therefore, a court should not look to the subjective motivations of the employees because they are irrelevant to determining what constitutes âservicesâ within the meaning of the [ADA].â81 According to the majority, because the plaintiffâs actions clearly posed a safety threat to the other passengers, the airlineâs decision to eject him from the flight ârelated toâ the âserviceâ of boarding and seating passengers, notwithstanding the airline employeeâs subjective, allegedly discriminatory motivations.

As the above case highlights, the preemption outcome in passenger discrimination cases often depends entirely on whether a particular jurisdiction employs a broad or narrow definition of âservice.â In order to find the plaintiffâs claims preempted by the ADA, the Huggar court first had to include âboarding and seating decisionsâ as cognizable âservicesâ under the ADAâs preemption clause. In a similar case, the U.S. District Court for the District of Massachusetts held that a passengerâs lawsuit alleging he was discriminated against on account of his handicap in connection with boarding on a particular flight was preempted by the ADA.82 Necessary to the courtâs decision was its reliance on the Fifth Circuitâs broad definition of âservice,â which explicitly refers to âboarding.â

Conversely, jurisdictions employing the Ninth Circuitâs narrow definition of âserviceâ will reach the opposite result under identical scenarios. For instance, the Ninth Circuit held a plaintiffâs disability discrimination claim against American Airlines based on the airlineâs refusal to allow the plaintiff to board without a doctorâs certificate (she was in a wheelchair and had a heart problem) was not preempted by the ADA.83 The courtâs analysis was probably over-simplistic; it simply held, âthe term âserviceâ does not refer to alleged discrimination to passengers due to their disabilities.â84 Consequently, whether a passenger discrimination lawsuit is preempted by the ADA may ultimately depend on the courtâs definition of âservice.â

FALSE ARREST/ IMPRISONMENT

Several courts have addressed the issue of whether the ADA preempts false imprisonment and false arrest claims, reaching divergent conclusions.85 These cases can, however, be reconciled.

Where the courts have held a plaintiffâs claim for false arrest or false imprisonment is preempted by the ADA, such cases involve incidents where the airline refused or failed to provide a service relating to the transportation of a passenger.86 In these cases, âwhere the crux of the claim was the airlineâs refusal to transport the passenger,â the courts have concluded that the claims related to the services of the airlines, and were therefore preempted by the ADA.87 This makes sense because all Circuit Courts of Appeals agree that âtransportationâ of passengers is a cognizable âserviceâ under the ADA.

Conversely, where the basis of a false arrest or false imprisonment claim âis that the airline caused the passenger to be arrested by authorities without a proper factual basis,â courts have held that such claims are not ârelated toâ an airline âservice.â88 For example, if âan airline held a passenger without a safety or security justification, a claim based on such actions would not relate to any legitimate service and would not be preempted.â89

OTHER INTENTIONAL TORT CLAIMS

The Circuit Court of Appeals for the Seventh Circuit, in Travel All Over The World, Inc., examined whether a travel agencyâs intentional tort claims against Saudi Arabian Airlines, arising out of the travel agencyâs unsuccessful attempts to arrange flights to Saudi Arabia for its clients, were preempted by the ADAâs express provision.90 The court organized the plaintiffâs claims into two categories: (1) defamation and slander; and (2) âotherâ intentional tort claims.91

With respect to the first category, the Seventh Circuit acknowledged that courts have reached âdivergent resultsâ concerning whether claims for slander and defamation are preempted by the ADA.92 Here, the plaintiff based its defamation and slander claims on the airline employeesâ making knowingly false verbal and written statements about the travel agency to the agencyâs clients; specifically, that the agency âwas not a reputable company, that [the agency] had not booked seats on Saudi for many of them, that [the agency] often lied to its clients about reserving seats for them, and thatâ the agencyâs president would not be there to help them.93

Even after adopting the Fifth Circuitâs broad definition of âservice,â the Seventh Circuit held the statements themselves were not airline âservicesâ within the meaning of the ADA.94 Citing the Supreme Courtâs opinion in Morales, the court explained: âIt is difficult for us to envision how tort claims based on an airlineâs knowingly false statements about a travel agency would have even a âtenuous, remote or peripheralâ economic effect on the rates, routes, or services that the airline offers.â95 Furthermore, although the statements refer to the travel agencyâs services, the court held they certainly do not refer to the airlineâs rates, routes, or services.96 Therefore, the plaintiffâs defamation and libel claims were not preempted by the ADA.

With respect to the second category of âotherâ intentional tort claims, including intentional infliction of emotional distress, tortious interference and fraud, the Seventh Circuit reached a different opinion. Only where these claims are based upon the same slanderous and defamatory comments that the court already found not preempted, could such claims withstand preemption scrutiny.97

Yet, the Seventh Circuit doubted this would hold true for the plaintiff in Travel All, as with most plaintiffs. Instead, the âotherâ intentional tort claims were most likely âbased, at least in part, on [the airlineâs] canceling the confirmed tickets of [the agencyâs] clients and requiring these clients to purchase their tickets directly through [the airline].â98 To the extent that the plaintiffâs intentional tort claims rely on this âconductâ of the airline, rather than the airline employeeâs allegedly slanderous and defamatory âcomments,â the court held such claims âexpressly refer to airline âservices,â which include ticketing as well as the transportation itself,â and are therefore preempted by the ADA.99 Again, this holding depends entirely on the courtâs adoption of the Fifth Circuitâs broad âserviceâ definition in Hodges, as opposed to the Ninth Circuitâs narrow definition of âserviceâ in Charas.

CONCLUSION

The ADAâs preemption clause continues to cause confusion and divergent opinions throughout our nationâs courtrooms. The fundamental problem concerns the seemingly benign phrase ârelated to a price, route, or serviceâ of an air carrier. The Supreme Court has done little to clear the fog surrounding this issue. Aside from expressly declining the opportunity to define âservice,â the Courtâs interpretation of the phrase ârelated toâ has recently come into question.

In Morales, the Supreme Court interpreted the ârelated toâ language of the ADA broadly, based largely on the âbroad scopeâ previously applied to the similarly worded ERISA preemption clause.100 Yet, in recent years the Supreme Court has been narrowing the reach of ERISAâs preemption provisions.101 Indeed, the phrase ârelated toâ in ERISAâs preemption clause âappears to be developing, to some degree, to mean whether state law actually âinterferesâ with the purposes of the ERISA legislation.â102 Although the literal text of ERISAâs preemption clause is âclearly expansive,â like the ADA, the Supreme Court has held that for practical purposes the statute must be interpreted more narrowly, âlest its reach stop nowhere.â103 Analogously, it is unclear whether the ADAâs ârelated toâ phrase should likewise receive a narrower interpretation to mean: whether state law actually interferes with the purpose of the ADA.

The larger question involving the ADA preemption clause concerns the proper definition of âservice.â The Supreme Court has expressly declined to answer the question, despite the objections of three Justices.104 If the Court is not going to answer this question, Congress should. A clear definition of âservice,â from either the Supreme Court or the Legislature, âwould provide needed certainty to airline companies.â105

The question becomes: What definition of âserviceâ should the Supreme Court or Congress adopt for the ADAâs preemption clause? This question must be answered in light of the fundamental purpose behind the underlying statuteâcourts should look to the objectives of the ADA as a guide to the scope of state law that should survive. The ADA is an economic deregulation statute designed to promote competitive rates, routes and services among the nationâs airlines.106 As such, only those actions directly impacting the airlinesâ ability to provide competitive rates, enter new markets, and provide effective transportation to consumers should be preempted by the ADA.

The Ninth Circuitâs narrow definition of âservice,â which encompasses the âprices, schedules, origins and destinations of the point-to-point transportation of passengers, cargo or mail,â best aligns with the purpose of the underlying ADA statute. Furthermore, this definition comports with the Supreme Courtâs approach to express preemption clause analysis: âthe familiar principle of expression unius est exclusio alterius.â107

Neither the language nor the history of the ADA suggests that Congress was attempting to displace all state law tort causes of action against the airlines; nor should the preemption clause act as a safe harbor against claims having only a tenuous impact on airline services.108 The vast majority of state law intentional tort claims cannot be said to frustrate the goal of economic deregulation in the airline industry. Furthermore, such claims do not affect a particular airlineâs competitive posture any more so than a lawsuit affects any corporation in America. Accordingly, such actions should fall outside the scope of federal preemption under the ADA.

1 For a good discussion of the ADAâs legislative history, see Daniel H. Rosenthal, Legal Turbulence: The Courtâs Misconstrual of the Airline Deregulation Actâs Preemption Clause and the Effect on Passengersâ Rights, 51 Duke L.J. 1857, 1869-1872 (2002).

2 Pub. L. No. 85-726, 72 Stat. 731 (later codified as amended at 49 U.S.C. Â§Â§ 40010-44310 (1994)).

3 Matt Andersson, The New Airline Code 62-64 (iUniverse, Inc. 2005).

4 49 U.S.C. Â§ 1506 (current version at 49 U.S.C. Â§ 40120 (c)).

5 Morales v. Trans World Airlines, Inc., 504 U.S. 374, 378 (1992) (citing 49 U.S.C.App. Â§Â§ 1302 (a)(4), 1302 (a)(9)).

6 49 U.S.C. app. Â§Â§ 1301-1557 (1988).

7 Matt Andersson, The New Airline Code 67 (iUniverse, Inc. 2005).

8 Morales, 504 U.S. at 378; See also Trinidad v. American Airlines, Inc., 932 F. Supp. 521 (S.D.N.Y. 1996) (stating that the purpose of ADAâs preemption clause was to prevent states from interfering with the development of an air transportation system driven to higher levels of innovation and efficiency by economic competition).

9 49 U.S.C. Â§ 41713 (1997) (emphasis added).

10 49 U.S.C. Â§ 40120 (c); Chrissafis, 940 F. Supp at 1296.

11 Hodges v. Delta Airlines, Inc., 44 F.3d 334, 337 (5th Cir. 1995); Morales, 504 U.S. at 425 (Stevens J., dissenting).

12 Morales, 504 U.S at 385.

13 See Matthew J. Jelly, Federal Preemption by the Airline Deregulation Act of 1978: How do State Tort Claims Fare?, 49 Cath. U. L. Rev. 873 (2000).

14 U.S. const. art. VI Â§ 1, cl. 2.

15 See Susan D. Hall, Preemption Analysis After Geier v. American Honda Motor Co., 90 Ky. L.J. 251 (2002).

Earn Airline Rewards With Credit Cards

Posted on 22 June 2010. Tags: Airline, Cards, Credit, Earn, Rewards

by Richard Moross

Earn Airline Rewards With Credit Cards

You may have heard of frequent flyer programs, where participants earn points which award free airfares and benefits not available otherwise. But did you know that you do not have to actually fly in an airplane to earn these rewards?

There are many credit card companies today which offer customers the benefit of frequent flyer points. These credit cards have a special partnership with designated airline companies, awarding points to consumers based on certain types of purchases, cash advances, or other transactions. By making regular, everyday purchases, cardholders receive additional points. Different cards will offer different benefits or incentives. Participating cardholders commonly earn one or two free airline tickets every year.

Airline frequent flyer rewards credit cards come in two distinctive types. The first type of card is issued through an affiliated airline carrier, and is a good option for those who travel often. These cards are also wonderful for those who fly regularly for business purposes. If you have a tendency to use different airlines, or if you do not travel often, then you would be wise to choose the second type of card, which awards all-inclusive points. With this type of card, you will be allowed to use your frequent flyer points for travel on any airline, rather than being obligated to any one particular airline company.

Most major credit card companies offer frequent flyer incentive programs. For example, American Express offers a credit card with no expiration date on corresponding airline points, with double rewards for dining, travel, leisure, or entertainment purchases. A card through Bank of America offers no black out dates and rewards for all types of purchases. Visa, MasterCard, and Discover cards also have numerous cards through various companies, many of which also offer frequent flyer incentives.

If you are a frequent traveler, and tend to use credit cards during your excursions, then it makes logical sense to transfer your balances to a credit card which offers miles rewards. You will earn free travel incentives as a reward for what you are already doing, using your credit card! Airline credit cards also tend to offer exceptional interest rates, quality customer service, and amazing travel opportunities. Most cards also have no restrictions or blackout dates when it comes to using the accrued frequent flyer points.

Airline rewards credit cards are the most popular type of plastics, according to recent cardholder polls. Naturally so, since these cards were the original companies to offer rewards. In order to earn the very best incentives, there are a few tips and tricks to follow. Make sure to pay your bills in full every month. Choose a card with flexible reward schemes. Do you homework to discover the various benefit packages, such as special purchase incentive, redemption policies, or promotions.

Regardless of which frequent flyer airline rewards credit card that you choose, always remember that these cards have credit fees and a corresponding APR rate, just as any other card does. Keep careful records of your purchases and related point earnings, so that you always know where you stand. Pay close attention to the conditions and terms of the card, so that your hard earned rewards are not in vain!

Learn more about frequent flyer programs and airline rewards at www.AirlineRewards.com

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