Plaintiff, who is blind, requested but did not receive boarding assistance from defendant air carrier's employee and, while attempting to board the aircraft without assistance, tripped and fell on the ramp leading to the aircraft. Plaintiff filed a state court negligence action against defendant. Defendant removed the matter to federal court and filed a motion to dismiss on the grounds that that the Air Carrier Access Act of 1986 ("ACAA") preempted plaintiff's state law negligence claims and did not provide plaintiff with a private right of action. Plaintiff filed a motion to remand the case back to state court. The federal court granted plaintiff's motion to remand, holding that the ACAA did not completely preempt plaintiff's state law negligence claims but only preempted certain state law standards of care with regard to assistance to passengers. Baugh v. Delta Air Lines, Inc., 2015 WL 761932 (N.D. Ga. Feb. 23, 2015).