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97 The Court declared that "both cases are inappositethe first because it involved a pre-emption provision much broader than the Labeling Act's, and the second because it involved precisely the type of state rule that Congress had intended to pre-empt." 98 In Wolens , the preemption provision prohibited states from enacting or enforcing any law "relating to rates, routes, or services of any air carrier." The Court in Wolens concluded that the phrase "'relating to' indicates Congress' intent to pre-empt a large area of state law to further its purpose of deregulating the airline industry." 99 Thus, the Court concluded that Cipollone is not inconsistent because the phrase "based on" describes a more direct, but-for causal relationship than "relating to," which is broader and synonymous with "having a connection with." 100 The Court in Riege l held that the Medical Device Amendments of 1976 (MDA) preempts certain suits under state tort law

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