Executive Summary: On September 21, 2015, the U.S. Court of Appeals for the Eleventh Circuit held that the Airline Deregulation Act (ADA) does not preempt Miami-Dade County’s Living Wage Ordinance (LWO). Amerijet Int’l, Inc. v. Miami-Dade Cnty., No. 14-11401 (11th Cir. Sept. 21, 2015). This means that airlines that use the facilities of the Miami International Airport will have to comply with the LWO with regard to those employees who perform “covered services” for other airlines. The LWO remains inapplicable to airlines providing such services on their own behalf, however. The Eleventh Circuit joins the Ninth Circuit in interpreting the ADA’s definition of “services” narrowly, perhaps setting the stage for Supreme Court review.