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Until 1978, the Federal Aviation Act of 1958 (FAA), 72 Stat. 731, as amended, 49 U. S. C. App. 1301 et seq. (1988 ed. and

Until 1978, the Federal Aviation Act of 1958 (FAA), 72 Stat. 731, as amended, 49 U. S. C. App. 1301et seq.(1988 ed. and Supp. V), empowered the Civil Aeronautics Board (CAB) to regulate the interstate airline industry. Although the FAA, pre-1978, authorized the Board both to regulate fares and to take administrative action against deceptive trade practices, the federal legislation originally contained no clause preempting state regulation. And from the start, the FAA has contained a "saving clause," 1106, 49 U. S. C. App. 1506, stating: "Nothing . . . in this chapter shall in any way abridge or alter the remedies now existing at common law or by statute, but the provisions of this chapter are in addition to such remedies." In 1978, Congress enacted the Airline Deregulation Act (ADA), 92 Stat. 1705, which largely deregulated domestic air transport. "To ensure that the States would not undo federal deregulation with regulation of their own,"Moralesv.Trans World Airlines, Inc.,504 U. S. 374, 378 (1992),the ADA included a preemption clause which read in relevant part: "[N]o State . . . shall enact or enforce any law, rule, regulation, standard, or other provision having the forceand effect of law relating to rates, routes, or services of any air carrier . . . ." 49 U. S. C. App. 1305(a)(1). This case is our second encounter with the ADA's preemption clause. In 1992, inMorales,we confronted detailed Travel Industry Enforcement Guidelines, composed by the National Association of Attorneys General (NAAG). The NAAG guidelines purported to govern,inter alia,the content and format of airline fare advertising. SeeMorales,504 U. S., at 393-418(appendix to Court's opinion setting out NAAG guidelines on air travel industry advertising and marketing practices). Several States had endeavored to enforce the NAAG guidelines, under the States' general consumer protection laws, to stop allegedly deceptive airline advertisements. The States' initiative, we determined, "`relat[ed] to [airline] rates, routes, or services,' "id.,at 378 379 (quoting 49 U. S. C. App. 1305(a)(1)); consequently, we held, the fare advertising provisions of the NAAG guidelines were preempted by the ADA,id.,at 391. For aid in construing the ADA words "relating to rates, routes, or services of any air carrier," the Court inMoralesreferred to the Employee Retirement Income Security Act of 1974 (ERISA), which provides for preemption of state laws "insofar as they . . . relate to any employee benefit plan." 29 U. S. C. 1144(a). Under the ERISA, we had ruled, a state law "relates to" an employee benefit plan "if it has a connection with or reference to such a plan."Shawv.Delta Air Lines, Inc.,463 U. S. 85, 97 (1983).Moralesanalogously defined the "relating to" language in the ADA preemption clause as "having a connection with, or reference to, airline `rates, routes, or services.' "Morales,504 U. S., at 384. TheMoralesopinion presented much more, however, in accounting for the ADA's preemption of the state regulation in question. The opinion pointed out that the concerned federal agenciesthe Department of Transportation (DOT)and the Federal Trade Commission (FTC)objected to the NAAG fare advertising guidelines as inconsistent with the ADA's deregulatory purpose; both agencies,Moralesobserved, regarded the guidelines as state regulatory measures preempted by the ADA. Seeid.,at 379 (DOT and FTC);id.,at 386 (DOT);id.,at 390 (FTC).Moralesemphasized that the challenged guidelines set "binding requirements as to how airline tickets may be marketed," and "imposed [obligations that] would have a significant impact upon. . . the fares [airlines] charge."Id.,at 388, 390. The opinion further noted that the airlines would not have "carte blancheto lie and deceive consumers," for "the DOT retains the power to prohibit advertisements which in its opinion do not further competitive pricing."Id.,at 390-391.Moralesalso left room for state actions "too tenuous, remote, or peripheral . . . to have pre-emptive effect."Id.,at 390

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