In re: Southwest Airlines Co. Flight Disruption Litigation
United States District Court for the Southern District of California
2024 WL 3281288 (2024)
- Written by Jamie Milne, JD
Facts
Southwest Airlines Company (Southwest) (defendant) was a Texas corporation headquartered in Dallas, Texas. During the 2022 to 2023 winter holiday season, Southwest engaged in mass flight cancellations. Passengers whose flights had been canceled (plaintiffs) filed a class-action suit against Southwest, asserting various claims, including a claim for breach of the implied covenant of good faith and fair dealing. Southwest moved to dismiss the passengers’ claims, citing its Contract of Carriage, its standard contract with passengers. The contract included a choice-of-law clause stating that any disputes were governed by Texas law except in situations in which federal law preempted state law. Texas law did not impose a duty of good faith and fair dealing in contracts unless the contract expressly included such a duty or there was a special trust relationship between the parties. Neither applied to the Contract of Carriage. However, the passengers argued that California law should govern because Texas law was contrary to California’s policy of recognizing an implied covenant of good faith and fair dealing in every contract. Consequently, as a threshold matter when ruling on the motion to dismiss, the district court addressed the enforceability of the choice-of-law clause.
Rule of Law
Issue
Holding and Reasoning (Battaglia, J.)
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