Congress enacted the Airline Deregulation Act in 1978 to deregulate the domestic airline industry. The law prohibits states from enforcing laws “related to a price, route, or service of an air carrier.” 49 U.S.C. § 41713(b)(1) (2012). In American Airlines, Inc. v. Wolens, 513 U.S. 219 (1995), the Court held that states may not impose rules regarding fares, routes, or services, but may allow remedies for breaches of obligations the airlines took, even when the breach is related to fares, routes, or services. Further, the Supreme Court in Northwest, Inc. v. Ginsberg, 134 S. Ct. 1422 (2014) identified the differences between voluntary contracts and obligations imposed by state law. In Hickox-Huffman v. U.S. Airways, Inc., No. 11-16305, 2017 U.S. App. Lexis 7847, 2017 WL 1658487 (9th Cir. Cal. May 3, 2017), the Ninth Circuit held the agreement between the plaintiff and defendant was a routine offer and contract that the airline voluntarily undertook to deliver the plaintiff’s bag when she landed. Plaintiff’s bag was delayed one day and she sought recovery for the baggage fee of $15 she paid the airline. As a voluntarily assumed contract, state remedies for a breach of contract claim are “not preempted by the Airline Deregulation Act.” Hickox-Huffman, 2017 WL 1658487, at *5. The case has been reversed and remanded and the question of class certification has not been answered. Parties should also look to the Department of Transportation for recent regulations on domestic baggage liability with different effects for lost baggage. Analysis will also be different in international law under the Montreal Convention.