In Stewart v. Travelers Corp., the United States Court of Appeals for the Ninth Circuit held that a private remedy rather than only criminal sanctions should be implied for a violation of section 1674(a) of Title 15 of the United States Code. As a response to the dilemma of no specifically mentioned private remedy, federal courts have developed a policy of implying a civil remedy for violations of statutory prohibitions like section 1674(a). The court's opinion was based on the Texas & Pacific Railway v. Rigsby principle and the line of federal cases that have developed from it.

I. Introduction

II. The Facts

III. The Implication Principle

IV. The Stewart Result

V. Conclusion