1. Facts
1.1. Parties
1.1.1. Susan Schneberger, Lacy Stidman and Johnny Trent (Plaintiff) v. Air Evac EMS, Inc. and Eagle Med, LLC (Defendant)
1.2. What Happened?
1.2.1. Plaintiffs sued for breech of implied contract, money had and received, and violation of the Oklahoma Consumer Protection Act. They also sough declaratory and injunctive relief.
2. Issue
2.1. Are the rates of Air Evac EMS considered excessive as a matter of Oklahoma law?
3. Rule of Law
3.1. Preemption under the ADA
3.1.1. A fundamental principle of the Constitution is that Congress has the power to preempt state law.
3.1.1.1. Pursuant to the Supremacy Clause, state law that conflicts with federal law has no effect.
3.1.1.1.1. It is therefore well-established that within Constitutional limits Congress may preempt state authority by so stating in express terms.
4. Analysis
4.1. The Plaintiff is arguing that Defendants never disclosed their rates.
4.1.1. The Plaintiff claimed that the Defendants charged inflated prices that bore no reasonable relationship to the services rendered, thereby breaching implied contracts, including the implied covenant of good faith and fair dealing.
4.1.1.1. Plaintiff maintains that Defendants' prices are unreasonably high under Oklahoma law.
4.2. Defendants attempts in unrelated cases to recover on unpaid accounts by bringing breach of contract claims do not now estop Defendants from challenging Plaintiff's breach-of-implied-contract theory here.
4.2.1. The Defendant believe they are entitled to the full charges.
4.2.1.1. The Defendant continued to claim preemption under ADA.
5. Conclusion
5.1. The courts ruled in favor of the Plaintiff, stating that ADA preempts the plaintiffs' claim.
6. Impact
6.1. American Airlines (Plaintiff) v. Myron Wolens (Defendant) appeal
6.1.1. Original case: Members of airline's frequent flyer program brought class action against airline for breach of contracts and violations of Illinois' Consumer Fraud and Deceptive Business Practices Act, seeking injunctive relief against airline's retroactive modification of program and seeking damages.
6.1.1.1. The Circuit Court, Cook County denied motion to dismiss but granted motion for certification of quesition for interlocutory appeal. The Illinois Appellate Court, affirmed the denial of the motion to dismiss, but determined that federal law preempted the claim for injunctive relief. Certificate of importance to permit immediate review was issued.
6.1.1.1.1. The Illinois Supreme Court affirmed.