Regulation of Business – Jurisdiction of the Civil Aeronautics Board and the Federal Trade Commission – Investigations in the Interest of the Public

Petitioner, American Airlines, filed a memorandum with the Civil Aeronautics Board requesting that respondent’s request for registration of the name North American Airlines be denied. Section 411 of the Civil Aeronautics Act provides that the board has the authority to prevent air carriers from engaging in unfair methods of competition in commerce and unfair or deceptive acts or practices, and may issue a complaint against any air carrier when it shall appear to the board that a proceeding by it would be in the interest of the public. The board found that the public was confused as to the origin of the two transport services, and that the speed of air travel may be diminished by the confusion when passengers check in for flights or attempt to retrieve baggage from the wrong carrier, or if passengers should direct inquiries to the wrong service. On the basis of this finding the board ordered respondent to desist from using the trade name North American. The order was set aside by the Court of Appeals for the District of Columbia on the ground that the proceeding was not in the public interest. On certiorari to the Supreme Court, held, reversed. The complaint was in the public interest as there was confusion in the minds of the public as to the source of the transport systems. American Airlines v. North American Airlines, 351 U.S. 79 (1956).