Sheehan v. Bowden

Is an "airplane scheme" a pyramid sales structure under Alabama law?


The Alabama Supreme Court held that an airplane scheme was a pyramid sales structure and constituted a deceptive act under state law. The airplane "flew” primarily based on the inducement of others purchasing the right to induce third parties to join the scheme. The sale of rights in this manner was defined as a good, and was "in the conduct of trade". The scheme violated the state deceptive practices act.

The full case and case summary are available online at:

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Published In: Civil Procedure Updates, MLM / Direct Sales Updates, MLM Consulting / Network Marketing Updates

Reference Info:State, 11th Circuit, Alabama | United States

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