2031, 119 L.Ed.2d 157 (1992), Congress enacted § 1305(a)(1) which preempts state laws "relating to the rates, routes, or service of any air carrier. However, the scope of this preemption has been a source of considerable dispute since its enactment. In our own circuit, we have addressed the issue on several occasions. Prior to Harris, we held that the ADA did not preempt state law tort claims that were only “tenuously connected” with airline deregulation. See Lathigra v. British Airways PLC, 41 F.3d 535, 540 (9th Cir.1994) (looking to congressional intent, the panel concluded that the ADA did not preempt state tort actions for negligent reconfirmation because they did not undermine the goals of airline deregulation.); West v. Northwest Airlines, Inc., 995 F.2d 148, 151 (9th Cir.1993) (<HOLDING>). However, in 1995, we took a different
holding that recovery is limited to actual compensatory damages holding that when compensatory damages are nominal a much higher ratio of punitive damages to compensatory damages can be contemplated holding ada claim was discharged holding that state law tort claim for compensatory damages was too tenuously connected to airline regulation to trigger preemption under the ada holding that punitive damages do not need to be proportional to compensatory damages