Edwards v. Sun Country, Inc.
- Patrick Schiltz
- 0:25-cv-02624
- U.S. District Court · District of Minnesota
- 3
In Edwards v. Sun Country, Inc., Chief Judge Schiltz granted plaintiff Sandy Edwards's motion to send her airline injury case back to state court, finding no federal question jurisdiction.
Airline passengers who file state-law injury claims against commercial air carriers in state court may be affected by this ruling's analysis of when federal courts can exercise jurisdiction over such cases. Airlines that remove aviation tort cases to federal court based on the argument that federal aviation regulations create a substantial federal question face this court's conclusion that such regulation alone is insufficient to establish federal jurisdiction.
What happened
In Edwards v. Sun Country, Inc. (Case No. 25-CV-2624), passenger Sandy Edwards sued Sun Country Airlines in Minnesota state court after a February 4, 2022, emergency landing in Las Vegas allegedly injured her. Her claims — negligence, breach of contract, and product liability — were all based on state law. Sun Country removed the case to federal court, arguing that because commercial aviation is heavily regulated by federal law, the case necessarily raised a substantial federal question that belonged in federal court.
The court rejected that argument. To justify federal jurisdiction under the legal test from Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing, a case must involve a federal issue that is necessarily raised, actually disputed, substantial, and capable of resolution without upsetting the balance between federal and state courts. The court found that Sun Country had not identified any genuinely disputed issue of federal law — it had only pointed to federal regulations as the standards by which its conduct would be judged. The court relied on a Seventh Circuit decision, Bennett v. Southwest Airlines Co., which held that a tort case involving a fact-specific application of both federal and state rules does not clear this bar, and noted that no federal appeals court has held that national aviation regulation alone makes a crash-related tort claim arise under federal law.
Chief Judge Patrick J. Schiltz granted Edwards's motion to remand and ordered the case returned to the Minnesota District Court, Fourth Judicial District, under the federal statute governing remands of improperly removed cases.
The detailed version
- Edwards v. Sun Country, Inc. · No. 0:25-cv-02624
- Patrick Schiltz
- Sept. 15, 2025
Background
Plaintiff Sandy Edwards was a passenger on a Sun Country Airlines flight that made an emergency landing at Las Vegas's airport on February 4, 2022. Edwards alleges she was injured during the incident. She filed suit in Minnesota state court against Sun Country, Inc. (doing business as Sun Country Airlines) and Aerospace Rotables, Inc. (a Florida corporation), asserting state-law claims of negligence, breach of contract, and product liability.
Removal and the Jurisdictional Dispute
Sun Country removed the case to the United States District Court for the District of Minnesota. Removal is the procedural mechanism that allows a defendant to transfer a case filed in state court to federal court when federal jurisdiction exists. Sun Country's theory was that federal courts have jurisdiction under the doctrine of "substantial federal question" jurisdiction, derived from Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing, 545 U.S. 308 (2005). Under Grable, a state-law claim can be heard in federal court if it necessarily raises a federal issue that is: (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable of resolution without disrupting the congressional balance between federal and state courts. See also Gunn v. Minton, 568 U.S. 251, 258 (2013). Sun Country's argument was that because maintenance, inspection, service, testing, repair, certification, and operation of commercial aircraft are subject to comprehensive federal regulation, the lawsuit necessarily turns on federal law.
Edwards moved to remand — that is, to send the case back to state court on the ground that federal jurisdiction does not exist.
The Court's Analysis
Chief Judge Schiltz agreed with Edwards and rejected Sun Country's jurisdictional argument. The court focused on the second Grable element: whether a federal issue is "actually disputed." The court found that Sun Country had not identified any genuinely contested issue of federal law. Pointing to federal regulations as the benchmark for evaluating conduct is not the same as actually disputing a question of federal law.
The court found the case indistinguishable from Bennett v. Southwest Airlines Co., 484 F.3d 907 (7th Cir. 2007), in which the Seventh Circuit held that a case involving merely "a fact-specific application of rules that come from both federal and state law" does not satisfy Grable. The Seventh Circuit further noted in Bennett that no federal court of appeals has held — before or after Grable — that the national regulation of air travel converts a tort claim arising from a crash into one that "arises under" federal law. The court also cited Empire Healthchoice Assur., Inc. v. McVeigh, 547 U.S. 677, 700–01 (2006), for the proposition that Grable jurisdiction does not exist where a claim is "fact-bound and situation-specific."
The court expressly adopted the Bennett analysis and rejected Sun Country's position that the case falls within the category of substantial-federal-question cases.
Disposition
The court granted Edwards's motion to remand (ECF No. 12) and ordered the case remanded to the Minnesota District Court, Fourth Judicial District, pursuant to 28 U.S.C. § 1447(c), the federal statute governing remands of improperly removed cases. The opinion does not address the claims of defendant Aerospace Rotables, Inc. substantively, as the remand returns the entire case to state court.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.