The Airline Deregulation Act of 1978 (ADA) deregulated the domestic airline industry. Specifically, the ADA ended the dual administrative system, which allowed the states to regulate intrastate airfare and permitted the federal governmentโs Civil Aeronautics Board (CAB) to regulate interstate airfare. The Act also included a broad preemption clause to prevent the states from reimposing economic regulations on air travel. The preemption clause prohibits a โState . . . [from] enact[ing] or enforc[ing] any law, rule, regulation, standard, or other provision having the force and effect of law relating to rates, routes, or services of any air carrier.โ The Supreme Court has interpreted the scope of the ADAโs preemption clause expansively and concluded that only state law claims with a โtenuous, remote, or peripheralโ relationship to an airlineโs services survive preemption. Yet, the Supreme Court has never defined the key word: Service. Today, federal circuit courts disagree on the definition of โservice,โ and a majority have adopted the Fifth Circuitโs definition articulated in Hodges v. Delta Airlines, Inc. Applying the Supreme Courtโs expansive view of the ADAโs preemption clause, the Fifth Circuit defined the term โserviceโ as all bargained-for air carrier services, including โticketing, boarding procedures, provision of food and drink, and baggage handling, in addition to the transportation itself.โ The Fifth Circuitโs definition preempts almost all conceivable state law claims despite the Supreme Court excepting claims with a โtenuous, remote, or peripheralโ relationship to an airlineโs services from preemption. Consequently, the aviation industry largely evades state law. This Comment argues that courts should interpret the ADAโs preemption clause more narrowly to allow more state law claims to survive preemption, particularly claims arising from an airlineโs mishandling, delaying, or misplacing of a loved oneโs remains. As the COVID-19 pandemic claims lives and frustrates air travel, a perfect storm threatens to mishandle, delay, or misplace a loved oneโs remains. Grieving mothers, fathers, husbands, and wives are left without a legal remedy because the ADA shields the airline industry from liability concerning โbaggage handlingโ and the โtransportation itself.โ Courts should interpret the ADAโs preemption clause more narrowly based on the ADAโs clear purpose, the plain meaning of the ADAโs text, stare decisis, and the lawโs treatment of other entities that mishandle human remains.