Court of Appeals of Washington March 6, 2000, 44441-7-I (Howell v. Alaska Airlines, Inc.)

Grosse, J.

Claims of airline passengers seeking a refund of unused, and explicitly nonrefundable, tickets on the grounds of impossibility of performance, frustration of purpose, illusory promises, procedural and substantive unconscionability, breach of the duty of good faith and fair dealing, and unjust enrichment, are preempted under the Airline Deregulation Act of 1978 (ADA).