Worldwide: The Continuing Debate Regarding Complete Preemption And The Warsaw/Montreal Convention

In the United States, there has been uncertainty for decades in respect of the Montreal Convention 1999 ("the Montreal Convention") and the Montreal Convention's predecessor, the Warsaw Convention 1929 ("the Warsaw Convention"). This uncertainty stems from divergent United States court decisions as to the application of a doctrine called complete preemption to certain claims that are not expressly brought pursuant to the Conventions, but fall within the Conventions' scope.

With little binding precedent on the issue, differences in individual judges' interpretation of the Conventions have led to divergent opinions issued by different judges, sometimes in the same court, leading to unnecessary confusion as to whether US federal courts can hear these claims.

The Warsaw and Montreal Conventions

Like its predecessor, the Montreal Convention is a treaty that governs air carrier liability in the international transportation by air of passengers, baggage and cargo. Specifically, Articles 17 through 19 of the Convention address an air carrier's liability for death and injury to passengers "[taking] place on board the aircraft or in the course of any of the operations of embarking or disembarking," for damage to checked baggage and cargo when such checked baggage and cargo is in the air carrier's charge, and for "delay in the carriage by air of passengers, baggage, or cargo."

Prior to the Montreal Convention going into effect in 2003, the Warsaw Convention, the Montreal Convention's predecessor, had been subject to four Protocols amending its original text, one supplementary Convention, denunciation by the United States (subsequently withdrawn) and supplemental "private" agreements amongst carriers. Signed in 1999 and ratified in 2003, the Montreal Convention sought to update and "'harmonize the hodgepodge of supplementary amendments and intercarrier agreements of which the Warsaw Convention system of liability consists", and, like the Warsaw Convention, sought to achieve uniformity of the rules governing international carriage.

In US courts, an issue arose as to whether plaintiffs, asserting a claim within the Conventions' scope, must assert a claim pursuant to the Warsaw/Montreal Convention or whether they could assert any claim consistent with the Conventions. This is a significant issue because it could determine what court possesses jurisdiction to hear a plaintiff's claim.

The doctrine of complete pre-emption

Pursuant to its authority to determine the scope of federal courts' jurisdiction within the limits of Section 2 of Article III of the Constitution, the United States Congress enacted 28 U.S.C. § 1331, which provides federal district courts with original jurisdiction, known as "federal question" jurisdiction, over "all civil actions arising under the Constitution, laws, or treaties of the United States." Further, pursuant to 28 U.S.C. § 1332, federal district courts also possess original jurisdiction, known as "diversity jurisdiction," over civil actions between citizens of different states where the amount in controversy exceeds US$75,000.

Although the plaintiff, as the master of his/her complaint, can choose between filing an action in state or federal court, in general a defendant may remove an action filed in state court to federal court pursuant to 28 U.S.C. § 1441, which provides in pertinent part:

Except as otherwise expressly provided by Act of Congress, any civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed by the defendant or the defendants, to the district court of the United States for the district and division embracing the place where such action is pending.

Thus, generally, where a federal court has federal question or diversity jurisdiction (among other bases for original jurisdiction), a defendant may evoke 28 U.S.C. § 1441 to remove a case from state court to federal court.

However, under the "well-pleaded complaint rule," federal question jurisdiction does not exist unless a plaintiff affirmatively alleges a federal claim in his/her complaint (Caterpillar v. Williams, 482 U.S. 386, 392 (1987)). Thus, a plaintiff can avoid federal question jurisdiction by exclusively relying on state law in asserting his or her claims. An exception to the well-pleaded complaint rule is the doctrine of "complete preemption," which applies when "the pre-emptive force of [a federal law] is so powerful as to displace entirely any state cause of action [addressed by that law]." (Beneficial Nat'l Bank v. Anderson, 539 U.S. 1, 7 (2003) ("Beneficial")).

The Beneficial decision is the latest United States Supreme Court decision addressing the "complete preemption doctrine." In holding that provisions of the National Bank Act, a federal law setting forth the amount of interest a national bank may charge and the elements of a usury claim, completely preempted state law, the Court focused its inquiry on whether the US Congress intended that a federal cause of action would be exclusive. Finding such an intent, the Court, analyzing the text found that the provisions "provided an exclusive cause of action" and also "set forth procedures and remedies that govern that cause of action." The Court found further support for complete preemption in decisions it rendered in the late 19th and early 20th centuries finding the National Bank Act to exclusively govern this area of law and noting the "special nature" of national banks and the need for "[u]niform rules limiting the liability of national banks and prescribing exclusive remedies for their overcharges...".

The Warsaw and Montreal Conventions' exclusivity provisions

A debate amongst US courts as to whether the Warsaw and Montreal Conventions completely preempt state law centers on the Conventions' exclusivity provisions - Article 24 of the Warsaw Convention and Article 29 of the Montreal Convention.

An English translation of the governing French text of Article 24 of the original Warsaw Convention provides:

  1. In the cases covered by Articles 18 and 19 any action for damages, however founded, can only be brought subject to the conditions and limits set out in this Convention.
  2. In the cases covered by Article 17 the provisions of the preceding paragraph shall also apply, without prejudice to the questions as to who are the persons who have the right to bring suit and what are their respective rights.

Article 24, as amended by Montreal Protocol No. 4, provides:

  1. In the carriage of passengers and baggage, any action for damages, however founded, can only be brought subject to the conditions and limits set out in this Convention, without prejudice to the question as to who are the persons who have the right to bring suit and what are their respective rights.
  2. In the carriage of cargo, any action for damages, however founded, whether under this Convention or in contract or tort or otherwise, can only be brought subject to the condition and limits of liability set out in this Convention without prejudice to the question as to who are the persons who have the right to bring suit and what are their respective rights. Such limits of liability constitute maximum limits and may not be exceeded whatever the circumstances which gave rise to the liability.

As seen above, Article 24, as amended by the Montreal Protocol No. 4, removed the phrases "[i]n the cases covered by Articles 18 and 19" and "in the cases covered by Article 17" and added the phrase "whether under this Convention or in contract or tort or otherwise" in Article 24(2). In 1999, the United States Supreme Court in El Al Israel Airlines, Ltd. v. Tseng, 525 U.S. 155, 161, 175 (1999)("Tseng") held that Montreal Protocol No. 4 merely clarified, and did not alter, the Convention's rule of exclusivity and the Convention provided the exclusive remedies for claims brought within its scope. In so finding, the Court determined that the Montreal Convention preempted state law claims within its scope; the Court did not directly address whether the doctrine of complete preemption applied to the Montreal Convention (see Fadliah v. Societie Air France, 987 F.Supp.2d 1057, 1062 (C.D. Cal. 2013), noting that the Court considered the Convention's preemptive effect, but not in the context of complete preemption).

In Tseng, the Court considered state-law assault and false imprisonment claims brought by Tsui Yuan Tseng against El Al Israel Airlines within the Convention's scope, i.e., claims arising from injuries allegedly sustained during Tseng's international carriage in the course of embarking. Tseng alleged that she sustained mental injuries from an intrusive security search that was conducted as part of El Al's boarding procedures. Tseng and El Al agreed that Tseng was unable to recover under the terms of the Warsaw Convention because Tseng did not sustain the requisite "bodily injury" and the alleged search was not an "accident"; however, Tseng brought state-law-based claims asserting that she was entitled to recover under state law within the Convention's scope even when the Convention did not permit recovery.

In response, El Al, with support from the United States Department of Justice, argued that Article 24 of the original Warsaw Convention precluded a plaintiff, whose claim arose within the Warsaw Convention's scope but did not meet the Convention's conditions pertaining to liability, from bringing a state-law claim.

After a review of the "text, drafting history and underlying purpose of the Warsaw Convention," the Court agreed with El Al holding that:

Recovery for a personal injury suffered on board an aircraft or in the course of any of the operations of embarking or disembarking, if not allowed under the Convention, is not available at all.

Thus, the Court held that the Warsaw Convention preempted Tseng's state-law claims and that Tseng was not entitled to recovery.

Drafted the same year as Tseng and ratified four years later, Article 29 of the Montreal Convention is the successor to Article 24 of the Warsaw Convention providing:

In the carriage of passengers, baggage and cargo, any action for damages, however founded, whether under this Convention or in contract or in tort or otherwise, can only be brought subject to the conditions and such limits of liability as are set out in this Convention without prejudice to the question as to who are the persons who have the right to bring suit and what are their respective rights. In any such action, punitive, exemplary or any non-compensatory damages shall not be recoverable.

Article 29 of the Montreal Convention is similar to Article 24 of the Warsaw Convention, as revised by Montreal Protocol No. 4, combining the tw o paragraphs in Article 24 and preserving most of Article 24's wording. In fact, several US courts have found Article 29 of the Montreal Convention to clarify, not change, Article 24 of the Warsaw Convention, (see Paradis v. Ghana Airways Ltd., 314 F.Supp.2d 106, 111 (S.D.N.Y. 2004)).

The Warsaw/Montreal Convention complete preemption debate

US courts have debated the issue of whether the doctrine of complete preemption applies to the Warsaw and Montreal Conventions. An examination of case law on this issue reveals conflicting interpretations of the Tseng decision as well as the exclusivity provisions in the Warsaw and Montreal Conventions.

Courts finding complete pre-emption

The United States Supreme Court directs courts interpreting the language of a treaty to "begin with the text of the treaty and the context in which the written words are used." (Eastern Airlines v. Floyd, 499 U.S. 530, 534 (1991)). For interpreting "difficult or ambiguous passages," courts are allowed to look beyond a treaty's text "to the history of the treaty, the negotiations, and the practical construction adopted by the parties." Likewise, the Court, noting that a treaty ratified by the US is not only US law, but "an agreement among sovereign powers," has "traditionally considered as aids to its interpretation [of a treaty] the negotiating and drafting history (travaux preparatoires) and the post-ratification understanding of the contracting parties."

Several courts holding the Warsaw and/or Montreal Conventions to completely preempt state law, and thus finding an intention that the Convention be the exclusive cause of action for claims within its scope, have looked beyond the text of the Conventions' exclusivity provisions to the Conventions' negotiating history, drafting history and the post-ratification understanding of fellow signatories.

For instance, in Jack v. Trans World Airlines, Inc., 820 F.Supp. 1218 (N.D. Cal. 1993), the Northern District of California held that the Warsaw Convention completely preempted state-law claims after a thorough review of the Warsaw Convention's drafting history going back to draft convention text submitted to the International Technical Committee of Aerial Experts ("CITEJA") in the mid-to-late 1920s. Reviewing the Warsaw Convention's governing French text and noting that there were a variety of potential meanings that could be given to the word "conditions" as used in Article 24, the court found the review of the drafting history of the Warsaw Convention at CITEJA to indicate that the term "conditions" actually meant "fundamental basis", supporting a finding that actions must be brought "on the basis of the convention."

The Jack court further reviewed the drafting history of the Warsaw Convention at the Warsaw Conference in 1929, finding remarkable the "lack of discussion" regarding the Convention's exclusivity. In fact, the court found that a delegate of the United Kingdom, Sir Alfred Dennis, was the only individual directly addressing the issue, stating:

We have at the beginning of the article: "any action in liability, however founded, can only be brought subject to the conditions and limits set out in this Convention."

This is a very important stipulation which touches upon the very substance of the Convention, because it excludes recourse to common law; originally it was a separate article.

According to the court, this statement further supported the Court's finding that the Warsaw Convention completely preempted state law.

Likewise, in Fadhliah v. Societe Air France, 987 F.Supp.2d 1057 (C.D. Cal. 2013), noting the divide among courts over the meaning of the phrase "whether under this Convention or in contract or in tort or otherwise" in Article 29 of the Montreal Convention, the court turned to the drafting history of the Montreal Convention — its travaux préparatoires. While some courts finding no complete preemption interpreted the phrase to mean that a state law contract or tort action could be brought within the scope of the Convention, the court read a statement by the Chairman of the Montreal Conference on Article 29 to indicate that the phrase actually bolstered, not diluted, the Convention's preemptive effect.

The Fadhliah court also examined the post-ratification understanding of signatories to the Montreal Convention and found support for complete preemption from British Courts' interpretation of Article 29, specifically noting that in Hook v. British Airways Plc the court took the position that "there are no exceptions to the exclusivity of the Convention" and, on appeal, it was held that Article 29 "both provided and limited" the plaintiff's rights and remedies.

Moreover, courts holding that the Montreal Convention completely preempts state law have found complete preemption to be consistent with the Warsaw and Montreal Conventions' purpose of achieving uniformity (see Moran v. American Airlines, Inc., 2011 WL 13115633, at *5 (S.D. Fla. 2011 and Fadhliah, 987 F.Supp.2d at 1062). These courts tend to point to the Tseng decision, in which the Court found:

Given the Convention's comprehensive scheme of liability rules and its textual emphasis on uniformity, [the Court] would be hard put to conclude that the Warsaw delegates meant to subject air carriers to the distinct, nonuniform liability rules of the individual signatory nations.

Consistent with the Tseng court's finding that "reasonable views" expressed by the US Executive Branch should be given "great weight" in interpreting the Montreal Convention, courts have found information provided by the US Executive Branch to Congress during ratification to support a finding of complete preemption (see Fadhliah and Schaefer-Condumari v. U.S. Airways Gp., Inc., 2009 WL 4729882). In Fadhliah, the court noted the testimony of the Deputy Assistant Secretary of State for Transportation Affairs who testified:

in the clear language, [the Convention establishes] its exclusivity in the area of claims for damages arising in the international transportation of passengers, baggage and cargo.

Likewise, in Schaefer-Condulmari, the court cited an explanatory note to Article 29 submitted by the US Executive Branch to the US Congress during ratification which stated that the "Convention and its limits shall be applicable to all actions for damages arising in the carriage of passengers, baggage and cargo..." and that air carriers, as well as their servants and agents could not be "held liable outside the Convention under alternative tort or contract law theories."

Courts finding no complete pre-emption

In contrast, there have been several US courts, including those issuing recent decisions, holding the Warsaw and/or Montreal Convention to not completely preempt state law claims, (see Hoffman v. Alitalia-Compagnia Aerea Italiana S.P.A., 2015 WL 1954461 (D. N.J. April 28, 2015); Greig v. US Airways Inc., 28 F.Supp.3d 973 and Oganesyan v. American Airlines Cargo, 2013 WL 6229173 (C.D. Cal. 2013)); Constantino v. Continental Airlines, Inc., 2014 WL 2587526 at *3 (D.N.J. June 9, 2014); and Jensen v. Virgin Atlantic, 2013 WL 1207962 at *4 (N.D. Cal. March 25, 2013).

These courts found that the Warsaw and/or Montreal Convention's provisions apply under ordinary preemption, not complete preemption, and, as a result, the Convention is not a basis for removal to federal court. Some of these courts emphasize that the Tseng decision did not address complete preemption and that arguments citing Tseng in support of complete preemption conflate the doctrine of complete preemption with ordinary preemption.

Recent decisions finding against complete preemption tend to base their conclusions on the text of Article 29 of the Montreal Convention on its face – especially the phrase "whether under this Convention or in contract or in tort or otherwise" – finding it clearly allows for claims to be brought under both the Convention and local law.

US courts should find for complete pre-emption

US courts should resolve the longstanding debate in favor of a finding that the Warsaw and Montreal Conventions completely preempt state-law claims. Such a resolution would take into account the courts' differences in their interpretation of the Conventions' exclusivity provisions and a thorough analysis of the Conventions' text and drafting histories as well as the post-ratification understanding of other signatories and treaty interpretations provided by the US executive branch to Congress during the ratification process. Such a resolution would also be consistent with the Court's Beneficial decision.

As noted above, when interpreting treaties, courts are allowed to look beyond the treaty's text "to the history of the treaty, the negotiations, and the practical construction adopted by the parties" when interpreting "difficult or ambiguous passages." The decades-long debate as to the meaning of the Warsaw and Montreal Convention's exclusivity provisions with respect to complete preemption indicates the need to go beyond the text to determine whether complete preemption applies. Compare Rosenbrock, 2016 WL 2756589 at *19 (finding that "[b]y mandating that any action, no matter the basis, 'can only be brought' subject to its provisions, the Convention plainly establishes itself as the 'exclusive cause of action' for claims within its scope.") with Hoffman, 2015 WL 1954461, at *3 (D.N.J. April 28, 2015)(finding that "the inclusion of the phrase 'whether under this Convention or in contract or in tort or otherwise' in Article 29 implies that claims may be brought both under the Convention and not under the Convention."). However, recent decisions in which courts have found no complete preemption have gone no further than the face of the Conventions' text.

Further, recent decisions appear to overlook the fact that Article 29 of the Montreal Convention derives from the governing French text of Article 24 of the original Warsaw Convention. In fact, Article 29 of the Montreal Convention contains a lot of the same wording as the English translation of the governing French text of Article 24, including the phrases "any action for damages, however founded" and "brought subject to the conditions." As noted above, the Jack court, reviewing the French text, found ambiguity as to the word "conditions", ultimately finding that the wording supported a finding of complete preemption.

A finding of complete preemption is also consistent with the Beneficial decision. Like the statute at issue in Beneficial, an overarching purpose of the Warsaw and Montreal Conventions is achieving uniformity in an area of law. Moreover, like the National Bank Act in Beneficial which "form[ed] a system of regulations... all the parts [of which] are in harmony with each other and cover the entire subject," the Montreal and Warsaw Conventions establish "a detailed and unique system for adjudicating carriers' liability for personal-injury claims, their defenses to those claims, and the damages that passengers may recover." (Moran, 2011 WL 13116533 at *5; Beneficial, 539 U.S. at 10).


The decades-long debate as to whether the doctrine of complete preemption applies to the Warsaw and Montreal Conventions should end in favor of finding that the doctrine applies. Courts that have recognized the difference of opinion and have conducted a thorough review of the Conventions' drafting histories, post-ratification understanding of fellow signatories, and the US executive branch's interpretation of the treaty have found the doctrine of complete preemption to apply. A finding that the complete preemption doctrine applies to the Warsaw and Montreal Conventions would provide much needed clarity as to which US courts have jurisdiction over claims arising under the Conventions' scope.

The Continuing Debate Regarding Complete Preemption And The Warsaw/Montreal Convention

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