Sarah E. Wilbanks
Alternate image for Sarah E. Wilbanks

Sarah E. Wilbanks

Associate

Denver
303.825.7029

I concentrate my practice on representing airport clients, which involves advising public and private entities on a wide range of issues arising under federal law that touch on the firm’s regulatory, transactional, and litigation practices. I have particular experience with prelitigation dispute resolution, negotiating use and lease agreements with airlines and other airport users, and counseling clients in connection with their federal regulatory obligations. I have also been involved in litigation concerning airport operations.

Prior to joining Kaplan Kirsch, Sarah served as an Assistant Corporation Counsel for the City of Chicago Department of Law in the Aviation, Environmental, Regulatory & Contracts Division. While with the City of Chicago, her responsibilities focused on providing counsel to the Chicago Department of Aviation, the proprietor of Chicago O’Hare International and Midway International Airport.

Representative Experience

  • Serving as outside counsel for airport regulatory matters to private terminal operator at one of largest U.S. airports, including development of terminal concessions program and negotiation of airline agreements
  • Representing San Antonio International Airport in negotiation of airline agreements and advising on other airport regulatory matters
  • Assisting several airports in formulation of new Rules and Regulations and Minimum Standards
  • Represented Boise Airport in negotiation of new airline use and lease agreement and associated governance documents
  • Advised Tweed New Haven Airport Authority during negotiations with private terminal operator for new lease and development agreement on related airport regulatory matters, including development of Minimum Standards, Rules and Regulations, and airline agreements
  • Advised various airports on COVID-19 related matters including federal grant programs, concessions agreements, and other crisis management issues related to sponsors’ federal obligations

Prior to joining the Firm, Sarah:

  • Served as legal counsel in successful negotiations for new airline use and lease agreement at O’Hare International Airport that replaced 30-year-old airline use and lease agreement and authorized a new $8.5 billion capital plan to update and modernize O’Hare’s terminals
  • Advised the City of Chicago on the establishment, implementation, and enforcement of a regulatory program to authorize and regulate aeronautical service providers at O’Hare International Airport and Midway International Airport, including drafting of enabling legislation and accompanying administrative rules
  • Represented the City of Chicago in a wide range of state and federal litigation matters, including in its affirmative litigation against pharmaceutical companies seeking to hold them liable for their role in the opioid crisis; a qui tam case in federal court involving fraud uncovered on City contracts worth hundreds of millions of dollars; and various contractual disputes between the City and its contractors
  • Advised large airport system on issues related to the requirement of labor peace agreements and minimum wage requirements for airport employees

Resources and News

News

Presentations

Publications

  • Co-Author, TRANSPORTATION RESEARCH BOARD, AIRPORT COOPERATIVE RESEARCH PROGRAM, Legal Research Digest 45: Airport Customer Facility Charges: Analysis of Laws, Regulations, and Case Law (2023).