American Airlines v. Sabre affirmed an award of $15,000 in attorneys fees in connection with a remand order. No. 11-10759 (Sept. 5, 2012). The Fifth Circuit found that American’s antitrust claims did not create a substantial federal question within the meaning of Grable & Sons Metal Products v. Darue Engineering, 545 U.S. 308 (2005); thus, the trial court did not abuse its discretion with this fee award. Id. at 5. The Court also reviewed prior circuit precedent about the interplay of federal and state antitrust law in the removal context and found it consistent with affirmance here.
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