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: http://www.mlmlegal.com/legal-cases/Sheehan_v_Brown.php