Wash. Supreme Court published opinion — 897239.pdf

Citation: Wash. Supreme Court published opinion — 897239.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/897239.pdf ↗

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independent of whatever labor agreement might govern, are not pre-empted under the

RLA." Hawaiian Airlines, 512 U.S. at 257. Thus, our preemption analysis is the

same as above. We hold that Proposition 1, which establishes a minimum wage and

other employee protections, is not preempted by the RLA. Therefore, we affirm the

trial court.

C. The ADA Does Not Preempt Proposition 1

The trial court did not analyze whether the ADA preempts Proposition 1

because it found that state law preempted Proposition 1 at the Seattle-Tacoma

International Airport. Filo Foods argues that the ADA preempts Proposition 1

because Proposition 1 "has the force and effect of law related to air carrier services

... and ... 'prices' ... by dictating how much carriers must pay for the workers who

provide ... services." Filo Foods's Opening Br. at 45. We hold that the ADA does

not preempt Proposition 1 because Proposition 1 is not sufficiently "related to" airline

services and prices.

34
  FilaFoods,
LLC
 v.City
       
ofSeaTac
89723-9

Congress enacted the ADA in 1978, "determining that 'maximum reliance on

competitive market forces' would best further 'efficiency, innovation, and low prices'

as well as 'variety [and] quality ... of air transportation services."' Morales v. Trans

World Airlines, Inc., 504 U.S. 374, 378, 112 S. Ct. 2031, 119 L. Ed. 2d 157 (1992)

(alterations in original) (quoting former 49 U.S.C. App. §§ 1302(a)(4), (9), recodified

as 49 U.S.C. §§ 40101(a)(6), (12)). The ADA contains a preemption provision to

prevent States from undoing federal deregulation. 49 U.S.C. 41713(b)(1). Under that

provision, states "may not enact or enforce a law ... related to a price, route, or