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    Volume 33, Number 1

     

    Why DOT Should Interpret “Deceptive Practices” Using a “Reasonable Consumer” Standard

    David Heffernan and Brian Doll

    On February 28, 2020, DOT initiated a rulemaking to define “unfair or deceptive practices,” the statutory language modeled on section 5 of the Federal Trade Commission Act that provides DOT’s primary regulatory and enforcement authority over airline consumer practices. The authors explain why and how DOT should follow the FTC’s lead.

    Features

    Columns

    Editor’s Column

    David A. Berg

    Aparna B. Joshi represents employers in a wide variety of labor and employment matters. She has substantial experience advising aviation industry clients, representing airlines in federal court litigation under the Railway Labor Act, as well as in labor arbitrations, mediations, collective bargaining negotiations and proceedings before the National Mediation Board and the National Labor Relations Board. She also has significant experience representing clients in employment class action litigation and in international labor matters.

    Meet the New Editor

    Aparna Joshi, Partner, O’Melveny & Myers

    Aparna B. Joshi represents employers in a wide variety of labor and employment matters.She has substantial experience advising aviation industry clients, representing airlines infederal court litigation under the Railway Labor Act, as well as in labor arbitrations, mediations, collective bargaining negotiations and proceedings before the National MediationBoard and the National Labor Relations Board. She also has significant experience representing clients in employment class action litigation and in international labor matters.