U.S. Court of Appeals for the Eighth Circuit
Pennsylvania Insurance Company v. Federal Express Corporation
September 3, 2026
Summary
The Eighth Circuit affirmed the district court's judgment in favor of Pennsylvania Insurance, holding that the Airline Deregulation Act preempted the insurer's negligence, unjust enrichment, and civil theft claims, that no conversion occurred, that FedEx's $100 liability limitation was enforceable, that a valid contract existed between the Iron Horse Golf Club and FedEx, and that FedEx breached that contract by failing to deliver the watch. The court also affirmed the insurer's standing as a subrogee and third‑party beneficiary.