Wings Of Frequent Flyer Clipped.

An airline’s frequent flyer program contained a provision stating that an abuse of the program may result in cancellation of the member’s account. After the airline cancelled a member’s account, the member brought a class action alleging breach of the implied covenant of good faith and fair dealing. The United States Supreme Court held the Airline Deregulation Act of 1978 [49 U.S.C. § 41713] preempts plaintiff’s state law claim. (Northwest, Inc. v. Ginsberg (U.S. Sup. Ct.; April 2, 2014)134 S.Ct. 1422, [188 L.Ed.2d 538].)