How many times have we read in briefs, trial court orders, or in our own submissions to the court that include discussions about express preemption, field preemption, and conflict preemption? Aviation litigators argue preemption very frequently. A subset and related element to preemption is an unreasonable burden on interstate commerce. We know under Article VI to the Constitution of the United States of America that the laws of the United States are the supreme law of the land. We further understand that Article I, Section 8, Clause 13 gives Congress the authority to regulate commerce. While the author has read on numerous occasions the Supreme Court decision in City of Burbank v. Lockheed Air Terminal, Inc., 411 U. S. 624 (1973), I thought it would be interesting to review the trial court decision in Lockheed Air Terminal, Inc. v. City of Burbank, 318 F. Supp. 914 (C. D. Cal. 1970).