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In 1986, Congress enacted the Air Carriers Access Act ("ACAA" or "the Act") in an effort to prohibit commercial air carriers from discriminating against the nearly five million disabled Americans who require access to air transportation annually.' The main provision of the ACAA reads as follows: "No air carrier may discriminate against any otherwise qualified handicapped individual, by reason of such handicap, in the provision of air transportation."2 The Act defines a "qualified handicapped individual" as one who purchases a ticket, presents herself or himself for travel,

Implied Causes of Action under Federal Statutes: The Air Carriers Access Act of 1986