Watson v. Air Methods Corp., No. 15-1900 (8th Cir. 2017)
Annotate this CaseAfter plaintiff filed suit against Air Methods for wrongful discharge in violation of public policy, Air Methods removed the case to federal court and moved to dismiss based on the pre-emption provision of the Airline Deregulation Act (ADA), 49 U.S.C. 41713(b)(1). The district court relied on Botz v. Omni Air International, 286 F.3d 488 (8thCir. 2002), and dismissed the complaint. The Eighth Circuit reversed, holding that the ADA did not expressly preempt plaintiff's state-law wrongful-discharge claims involving post hoc reporting of alleged violations of air-safety regulations. To the extent that the court's opinion in Botz held otherwise, the court overruled it.
Court Description: Colloton, Author, for the Court En Banc] Civil case - Airline Deregulation Act. For the panel's opinion, see Watson v. Air Methods, Corp., 834 F.3d 891 (8th Cir. 2016). In an action alleging a common-law claim for wrongful discharge in violation of public policy, the district court erred in dismissing the complaint on the ground it was pre-empted by the pre-emption provision of the Airline Deregulation Act, 49 U.S.C. Section 41713(b)(1). Held: The Airline Deregulation Act does not expressly pre-empt plaintiff's state-law wrongful-discharge claim involving post-hoc reporting of alleged violations of air-safety regulations. To the extent the court's earlier opinion in Botz v. Omni Air International, 286 F.3d 488 (8th Cir. 2002)holds to the contrary, it is overruled.
This opinion or order relates to an opinion or order originally issued on August 24, 2016.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.