The Second Appellate District affirmed a judgment. The court held that the Airline Deregulation Act preempted a claim that the expiration date on an airline travel gift certificate violated state law.
Mitch Tanen bought a $100 travel certificate from Southwest Airlines Co. in February 2005. He attempted to redeem it 14 months later, after its stated expiration date. Southwest refused to honor the travel certificate. Tanen sued, asserting that the expiration date violated Civil Code §1749.5, which makes it unlawful to sell a gift certificate that contains an expiration date.
