The U.S. Supreme Court case American Airlines, Inc. v. Wolens et al., 1994 revolved around a dispute between the airline and its frequent flyer program members who alleged that changes to the program constituted breach of contract and violated consumer fraud statutes. The plaintiffs argued that they had accrued mileage points under certain terms which were later unilaterally changed by American Airlines, devaluing their earned benefits without notice or consent. The court ruled in favor of American Airlines stating that such disputes fell within the realm of federal law rather than state law due to the Airline Deregulation Act (ADA) passed in 1978, which preempts states from enforcing any laws related to "price, route or service" of an air carrier. However, it also held that claims for breach of contract could proceed as these did not involve enforcement of state policies but simply sought compensation for alleged breaches.

In the dissenting opinion for American Airlines, Inc. v. Wolens et al., Justice Stevens argued that the majority's decision to allow airlines to unilaterally alter their frequent flyer programs without being subject to state contract law was a misinterpretation of the Airline Deregulation Act (ADA). He contended that Congress did not intend for this act to shield airlines from basic principles of contract law and consumer protection when it passed ADA. The justice believed that allowing an airline company like American Airlines, which had entered into millions of contracts with its customers through its AAdvantage program, to change terms at will undermined fundamental fairness and equity in contractual relationships. Furthermore, he expressed concern over how such a ruling could potentially encourage deceptive practices by other businesses seeking similar protections under federal deregulation laws.