Case Explained: Non-Argument Calendar RAMON GONZALEZ FIGUEROA v. JETBLUE AIRWAYS CORPORATION

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-02

Docket: 0:24-cv-61178-AHS

The eleventh-circuit affirmed the district court’s dismissal with prejudice of Ramon Gonzalez Figueroa’s negligence claim against JetBlue Airways Corporation. The court held that the Airline Deregulation Act (“ADA”) preempts the plaintiff’s state-law common law negligence claim, which alleged that JetBlue negligently placed him on an uninvited-to-fly list in violation of Florida tort law. Applying the standard of review de novo for the dismissal and abuse of discretion for the denial of leave to amend, the court determined that Florida’s common law constitutes a “law” under 49 U.S.C. § 41713(b) and is “related to… service of an air carrier.” The court reasoned that JetBlue’s decision to deny Figueroa access to future transportation services constitutes an economic decision regarding the bargained-for provision of labor, thereby falling squarely within the ADA’s preemption scope. The court distinguished the plaintiff’s reliance on dicta from *Xiaoyun Lucy Lu v. AirTran Airways, Inc.*, noting that unlike a wrongful removal claim arising during a flight, Figueroa’s suit challenged the airline’s refusal to provide future services after his flight concluded. Because any amendment to the complaint would be futile given that additional factual details regarding the encounter with law enforcement would not alter the fundamental preemption analysis, the district court properly denied leave to amend. Consequently, the judgment of the district court is affirmed, leaving the claim dismissed permanently.

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