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Passenger may sue airline over frequent flier program

Federal aviation law does not preempt a passenger’s claim against an airline for a breach of the implied covenant of good faith and fair dealing, the 9th Circuit has ruled in reversing dismissal of a suit. The plaintiff was an active member of Northwest Airline’s frequent flier program for several years until the airline revoked his membership. He filed suit, arguing that the airline revoked his membership arbitrarily because he complained too frequently about its service

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