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Northern Illinois University Law Review


There are approximately 54 million disabled individuals in the United States. Those 54 million American citizens live their day to day lives differently than the average person, facing difficulties most others cannot comprehend. While legislation has come a long way in recent decades, one area that has remained stagnant is how we treat disabilities on airplanes. Despite legislation remaining relatively stagnant, judicial opinions have not. In fact, many United States Circuit Courts have determined that the Air Carrier Access Act, which provides limited protections on airplanes, does not confer a private cause of action for violations. As a result, the only remedy allowed for aggrieved airline passengers is through a complaint system set up by the Department of Transportation. No private remedy. No compensation. Only administrative inaction. This has proven to be a woefully insufficient remedy for direct harms to disabled individuals, creating a dire situation where the livelihoods of millions of Americans remain in jeopardy.

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College of Law

Suggested Citation

William Belles, Note, A Right to Fly: Navigating the Air Carrier Access Act and the Americans with Disabilities Act Following Alexander v. Sandoval, 44 N. Ill. Univ. L. Rev. 82 (2023).

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