Deveraturda v. Globe Aviation Sec. Services, 454 F.3d 1043 (9th Cir. 2006)
Virgil Deveraturda and other similarly situated employees, who were employed by Globe Airport Security Services to provide screening services at San Jose International Airport, were laid off as a result of the Aviation and Transportation Security Act of 2001. The employees were not given the 60 days’ notice provided under the WARN Act. The Ninth Circuit held the WARN Act did not apply because the layoff resulted from the government’s decision after September 11th to federalize airport security, a decision over which Globe had no control.