Case 3:15-cv-03749-D Document 1 Filed 11/19/15

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
SOUTHWEST AIRLINES CO.,

§
§
Plaintiff,
§
§
§
§
v.
§
§
TRANSPORT WORKERS UNION OF
§
AMERICA, AFL-CIO, LOCAL 555; GREG §
PURISKI; JERRY MCCRUMMEN;
§
ALFONSO SANTOYO; and JESSE SOTO, §
§
Defendants.
§

CIVIL ACTION NO. ______________
COMPLAINT

PLAINTIFF SOUTHWEST AIRLINES CO.’S ORIGINAL COMPLAINT
Jurisdiction
1.

This is an action for declaratory relief, damages, and a permanent injunction by

Plaintiff Southwest Airlines Co. (“Southwest” or the “Company”) in connection with
Defendants’ unlawful job action and disruptive activity in violation of the Railway Labor Act
(“RLA”), 45 U.S.C. § 151 et seq. The Court has jurisdiction over this action under 28 U.S.C. §§
1331 and 1337.
2.

Venue is proper in this judicial district under 28 U.S.C. § 1391(b) because a

substantial part of the events or omissions giving rise to the claims set forth herein occurred in
this judicial district and because Southwest and Defendant Transport Workers Union of America,
Local 555 maintain their business headquarters in this district.

PLAINTIFF SOUTHWEST AIRLINES CO.’S ORIGINAL COMPLAINT

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Parties
3.

Southwest is a corporation organized and existing under the laws of the State of

Texas and having offices and its principal place of business at 2702 Love Field Drive, Dallas,
TX 75235. Southwest is a “common carrier” by air engaged in interstate or foreign commerce
under 45 U.S.C. § 181 and is subject to the provisions of the RLA.
4.

Defendant Transport Workers Union of America, Local 555 (“TWU Local 555”

or the “Union”) is an unincorporated labor organization with its principal offices located at 2608
Inwood Rd., Suite 150, Dallas, TX, 75235. TWU Local 555 is the exclusive collective
bargaining representative under the Railway Labor Act of Southwest’s 11,279 ramp, operations,
provisioning and freight agents.
5.

The following Individual Defendants are officers of TWU Local 555 who act in

their identified positions pursuant to the TWU Local 555 By-laws: Greg Puriski, President; Jerry
McCrummen, Vice President; Alfonso Santoyo, Financial Secretary-Treasurer; and Jesse Soto,
Recording Secretary/Safety. Pursuant to the TWU Local 555 By-laws, the governmental powers
of the TWU Local 555 are vested in the aforementioned Individual Defendants. Puriski,
McCrummen, Santoyo and Soto each maintain offices and conduct the business of TWU Local
555 at the organization’s offices at 2608 Inwood Rd., Suite 150, Dallas, Texas 75235. These
activities were at all relevant times continuous and systematic, thus conferring general
jurisdiction over each of the Individual Defendants in this Court.
Southwest’s Airline Operations
6.

Southwest is a scheduled air carrier engaged in interstate and foreign

transportation of passengers and freight.
PLAINTIFF SOUTHWEST AIRLINES CO.’S ORIGINAL COMPLAINT – Page

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Southwest is one of the largest scheduled passenger airlines in the world and the

largest carrier in the United States in terms of originating domestic passengers boarded.
Southwest serves 97 destinations in cities throughout the United States and in seven additional
countries, operating over 3,600 flights every day. Southwest thus is an integral part of the
country’s air transportation systems, connecting and interchanging freight and passengers with
many other carriers, both inside and outside the airline industry. In 2014, Southwest transported
approximately 208 million pounds of cargo and carried an average of over 10 million passengers
every month.
8.

Southwest maintains substantial facilities and has an investment in operating

equipment and property exceeding hundreds of millions of dollars in value.
The Collective Bargaining Agreement
9.

Southwest and TWU Local 555 are parties to a collective bargaining agreement

that sets the rates of pay, rules, and working conditions for the 11,279 TWU Local 555represented ramp, operations, provisioning and freight agents employed by Southwest. The most
recent collective bargaining agreement (“CBA”) between Southwest and TWU Local 555 was
effective as of July 1, 2008 and became amendable under the RLA on June 30, 2011.
10.

Pursuant to Section 6 and Section 2, First of the RLA, the rates of pay, rules, and

working conditions under the CBA continue in effect while the parties negotiate for a successor
agreement. 45 U.S.C. §§ 156, 152, First. Accordingly, Southwest and TWU Local 555 remain
subject to a statutory status quo obligation under the RLA. Under Section 2, First, the RLA
imposes an affirmative legal duty on the union to make every reasonable effort to prevent strikes
or other concerted work actions, such as refusals to work.
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The RLA also sets forth a detailed sequence of steps that are required to occur

during the renegotiation of a collective bargaining agreement. In progression, those steps
include negotiations between the parties, National Mediation Board (“NMB”) mediation,
possibly binding arbitration, and possibly, investigation by a Presidential emergency board.
Only after all such efforts have been exhausted will the NMB “release” the parties from their
bargaining agreement, after which a 30-day “cooling-off” period is imposed. All of these efforts
must be resorted to before the parties will be permitted to engage in self-help, such as strikes or
other concerted refusals to work.
12.

Southwest and TWU Local 555 have been in collective bargaining negotiations

for modifications to the Agreement since July 12, 2011. The parties jointly filed for mediation
with the NMB on September 18, 2012, and the dispute was docketed as A-13677.
13.

Under the RLA, the NMB controls the pace of mediating disputes. At the

direction of the NMB, contract discussions temporarily were suspended on July 30, 2014 and
have continued to be suspended except for a single brief meeting during October 2015.
14.

Because the NMB has not released the parties, neither party is permitted to

engage in strikes, lockouts, or other economic self-help. Any such premature self-help violates
the RLA.
The Unlawful Job Action
TWU Local 555 Solicits and Encourages Bargaining Unit Members to
Engage in a Concerted Refusal to Report to Work
15.

In mid- and late October 2015, Southwest management representatives began

receiving reports that TWU Local 555 members actively were discussing the possibility of

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conducting a strike or “sick-out” during the week of Thanksgiving 2015, even though the NMB
has not released the parties from mediation. Southwest learned further that TWU Local 555’s
leadership planned to hold a strike preparation meeting near Southwest’s Los Angeles, CA
station in mid-November 2015, and that TWU Local 555 was encouraging unit members to
invoke the CBA’s leave provisions and procedures for obtaining short-notice, unpaid personal
absences (“Reported Personal Absences” or “RPA”) in order to attend the meeting.
16.

The procedure for utilizing a Reported Personal Absence is set forth in Article 23

of the parties’ CBA, which contains Southwest’s Attendance Policy. Under that policy,
bargaining unit members accumulate “points” based on the number of unapproved absences and
instances of tardiness that they incur. The Attendance Policy provides for progressive levels of
discipline based on the total number of points accumulated, ranging from 1 (“Letter of
Instruction”) to 7 (“Termination”).
17.

When an employee “no-shows” (i.e., absents himself or herself from work

without notice or approval), that employee is awarded 2 points under Article 23’s disciplinary
system. By contrast, employees who provide at least one hour prior notice that he or she will not
report to work (for reasons other than personal illness) are charged with an unpaid Reported
Personal Absence (“RPA”), rather than a no-show, and awarded only 1 point.
18.

Southwest’s Director of Labor Relations for Ground Operations and Provisioning

Michelle Jordan contacted TWU Local 555 President Greg Puriski on October 18 and 29, 2015
to discuss the rumors that bargaining unit members were planning a concerted refusal to report to
work. Puriski denied that any sick-out was planned, but stated that he had strongly encouraged
bargaining unit members to take time off from work in order to attend the strike meeting.
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On November 6, 2015, Southwest received a notice stating that TWU Local 555

would be holding the “Strike Preparation Summit” on November 18, 2015 in El Segundo,
California with members of TWU Local 555’s Negotiation and Education Committees. TWU
Local 555 also posted a flyer detailing the meeting on its website, http://www.twu55.org. The
flyer, entitled “No More Excuses!,” included a graphic of an automobile bearing a California
license plate with the word “STRIKE,” with a TWU 555 sticker in close proximity. See Ex. 1.
TWU Local 555 also tweeted the flyer, along with the phrase “Strike Prep #TWU555 Stay
Informed!,” from its Twitter account, @twu_555. TWU Local 555 expressly directed this tweet
to the Twitter accounts of several major news media organizations, including NBC News
(@NBCNews), ABC News (@abcnews), Fox News (@FoxNews), and CBS News
(@CBSNews). See Ex. 2.
20.

Jordan again contacted Puriski by email to inform him that Southwest considered

the coordinated mass use of Reported Personal Absences in order to attend the Strike Preparation
Summit an unlawful job action. Puriski denied that TWU Local 555 intended to do anything that
would disrupt Southwest’s operations.
21.

On Friday, November 13, 2015, Puriski held a meeting with bargaining unit

Ramp Agents at Southwest’s San Diego, CA station’s break room. In reference to the Strike
Preparation Summit, Puriski warned that “if we don’t have a big turnout you can forget about us
doing this again,” and stated that he is “tired of the excuses people are giving for not going to the
meeting.” Puriski counseled the Ramp Agents that they should attempt to use a Reported
Personal Absence in order to attend the Summit.
Bargaining Unit Members Conduct Coordinated Call-Outs On November 18, 2015
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By November 17, 2015, a significant number of Ramp Agents working out of

Southwest’s Burbank, CA station had called in RPAs for the November 18 Strike Preparation
Summit. The Company also learned that TWU Local 555 planned to stage similar coordinated
call-outs at Southwest’s Ontario, CA station.
23.

In order to ensure its continued service, Southwest attempted to obtain temporary

replacements from Southwest’s other locations. At the Union’s urging, however, many of those
individuals refused to come into the station. Southwest therefore enlisted a contingent team of
supervisory employees from a variety of locations as backup support at its Ontario and Burbank
stations.
24.

Late on the evening of November 17, 2015, Southwest Senior Director of Labor

Relations Naomi Hudson left a voicemail for Puriski informing him that Southwest had declared
a state of operational emergency for the Burbank, CA station due to the mass call-out of
bargaining unit employees at that location. When Puriski returned Hudson’s call later that night,
Hudson further informed Puriski that Southwest also was declaring a state of operational
emergency at Southwest’s Ontario, CA station based on the rumored planned callouts at that
location, and reiterated that Southwest considered the bargaining unit members’ conduct to
constitute an unlawful concerted refusal to work in violation of the RLA.
25.

In response, Puriski merely stated that he believed bargaining unit members’

callouts were permitted under the parties’ CBA.
26.

That same day, the TWU Local 555 Negotiating Committee distributed an email

to its members entitled “11-17-15 Polling Notification” stating that it would be selecting random

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samples of its members to participate in a “focus group telephone interview.” The email stated
that the purpose of the interview would be to identify member opinions relating to the contract
negotiations, including whether members were “prepared to participate in a public campaign
against Southwest Airlines.”
27.

The next day, November 18, 2015, a majority of bargaining unit members (110 in

total) absented themselves from work at four of Southwest’s airport stations across Southern
California, including Burbank, Ontario, Orange County, and Los Angeles by utilizing a Reported
Personal Absence, calling in sick, or no-showing. Indeed, at Southwest’s Burbank station not a
single Ramp Agent showed up for work on November 18.
28.

Due to Defendants’ unlawful, coordinated refusals to report to work, Southwest

expended significant sums in order to obtain temporary personnel coverage.
29.

Upon information and belief, TWU Local 555 has current plans to conduct a

similar concerted refusal to work at Southwest’s Orlando, FL station on Friday, November 20,
2015.
30.

Upon information and belief, TWU Local 555 members are planning additional

similar coordinated call-outs at multiple Southwest station locations for the first Sunday after the
Thanksgiving holiday, November 29, 2015. The first Sunday after the Thanksgiving holiday
typically is one of Southwest’s busiest flight days of the entire year.
31.

Upon information and belief, this campaign of coordinated, simultaneous use of

the Reported Personal Absence procedure by bargaining unit members at targeted Southwest
locations constitutes an unlawful attempt to force Southwest to submit to TWU Local 555’s
Section 6 contract negotiations demands.
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Irreparable Harm
32.

Defendants’ actions are intended to cause and may cause irreparable injury to

Southwest and to the public if they are not enjoined.
33.

The week leading up to the Thanksgiving holiday is one of the busiest travel

periods during the year. Southwest estimates that the following number of passengers is
scheduled to travel on Southwest on the following days: Friday, November 20: 383,859;
Saturday, November 21: 311,100; Sunday, November 22: 351,043; Monday, November 23:
348,804; Tuesday, November 24: 421,259; Wednesday, November 25: 428,433; Saturday,
November 28: 394,534; Sunday, November 29: 465,058; and Monday, November 30: 405,831.
34.

As TWU Local 555 is well aware, the unlawful refusal to work by bargaining unit

members during this period may result in the delay or cancellation of flights, which could
inconvenience thousands of passengers and adversely affect the national transportation system.
35.

When a concerted refusal to work forces Southwest to cancel flights, it recovers

little of the revenue it would have earned from passengers on those flights.
36.

Southwest also incurs expenses related to delays and cancellations through

increased labor expenses and costs related to providing customers with alternative travel, food,
luggage delivery and hotel expenses.
37.

Southwest’s experience has shown that passengers whose flights are cancelled

may not postpone their travel on Southwest but may make alternative arrangements on other
airlines. Southwest not only loses the revenue from the flight at issue, but for outbound
passengers, it may well lose the revenue that would be gained from the return flight as well. In
addition, passengers are more likely to book away from Southwest for their future travel plans.
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Thus, while the long-term revenue loss from a job action cannot be readily calculated, it is likely
to be profound and lasting.
38.

The irreparable harm that can result from a job action is not limited only to

Southwest’s operations. Southwest’s operations are a vital part of the national and international
passenger and freight transportation system which will be disrupted by any concerted call-out.
The resulting disruption would deprive the public of efficient and timely transportation services.
39.

In short, the damages and loss of goodwill that Southwest may suffer if TWU

Local 555’s unlawful job action is not enjoined are unquantifiable, immediate, and irreparable.
40.

As to each item of relief sought, greater injury will be inflicted on the public and

upon Southwest if such relief is denied than will be inflicted upon the Defendants by the granting
of the relief sought.
First Cause of Action – Railway Labor Act Violation
41.

Southwest hereby realleges and incorporates by reference the allegations

contained in the preceding paragraphs numbered 1 - 40 as if they were fully set forth in this
paragraph.
42.

The Defendants are attempting to change the rates of pay, rules and working

conditions provided for in the collective bargaining agreement between Southwest and TWU
Local 555 by engaging in unprotected concerted activity without first exhausting the RLA’s
major dispute resolution procedures.
43.

The concerted refusal to work by the Defendants, and those Ramp Agents acting

in concert with Defendants, constitutes a breach of TWU Local 555’s status quo obligation under
Section 6 of the RLA, 45 U.S.C. § 156, which prohibits the use of economic self-help prior to the
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expiration of the statutory negotiation and mediation procedures specified in Sections 5 and 6 of
the RLA. 45 U.S.C. §§ 155, 156.
44.

Southwest is entitled to damages for TWU Local 555’s unlawful concerted self-

help activity, as well as a permanent injunction to prevent the Defendants from continuing to
violate the status quo.
Second Cause of Action – Railway Labor Act Violation
45.

Southwest hereby realleges and incorporates by reference the allegations

contained in the preceding paragraphs numbered 1 - 40 as if they were fully set forth in this
paragraph.
46.

The job action by the Defendants constitutes a breach of the obligation under

Section 2 First of the RLA, 45 U.S.C. § 152 First, to “exert every reasonable effort to make and
maintain agreements concerning rates of pay, rules, and working conditions and to settle all
disputes,” so as to avoid any interruption to commerce or to Southwest’s operations.
47.

An injunction is the only practical and effective means to compel compliance with

the Defendants’ statutory duty under Section 2 First of the RLA, 45 U.S.C. § 152 First.
48.

Southwest is entitled to damages for TWU Local 555’s unlawful concerted self-

help activity, as well as a permanent injunction to prevent the Defendants from violating their
statutory duty under Section 2 First of the RLA, 45 U.S.C. § 152 First.
Third Cause of Action - Railway Labor Act Violation
49.

Southwest hereby realleges and incorporates by reference the allegations

contained in the preceding paragraphs numbered 1 - 40 as if they were fully set forth in this
paragraph.
PLAINTIFF SOUTHWEST AIRLINES CO.’S ORIGINAL COMPLAINT – Page

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50.

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The Defendants’ refusal to take all reasonable steps to prevent the members of its

organization from engaging in unlawful self-help activity constitutes a breach of their obligations
under Section 2 First of the RLA, 45 U.S.C. § 152 First, to “exert every reasonable effort to
make and maintain agreements concerning rates of pay, rules, and working conditions and to
settle all disputes,” so as to avoid any interruption to commerce or to Southwest’s operations.
51.

An injunction directing the Defendants to take all reasonable steps to prevent

and/or end unlawful self-help activity is the only practical and effective means to compel
compliance with the Defendants’ statutory duty under Section 2 First of the RLA, 45 U.S.C. §
152 First.
52.

Southwest is entitled to damages for TWU Local 555’s unlawful concerted self-

help activity, as well as a permanent injunction directing the Defendants to take all reasonable
steps to prevent and/or end the unlawful self-help activity, pursuant to Section 2 First of the
RLA, 45 U.S.C. § 152 First.
The Relief Requested
WHEREFORE, Southwest prays that this Court:
(1)

Issue a declaratory judgment holding that the Defendants’ conduct constitutes

unlawful self-help in violation of Section 6 and Section 2, First of the RLA, 45 U.S.C. §§ 156 &
152 First;
(2)

Award damages for the costs that Southwest has incurred in responding to the

Defendants’ illegal job action, including but not limited to the costs of obtaining personnel
coverage due to the TWU Local 555 bargaining unit’s coordinated call-outs on November 18,

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2015 and any subsequent illegal job actions or coordinated efforts to disrupt Southwest’s
operations;
(3)

Issue a permanent injunction restraining and enjoining Defendant TWU Local 555

and the individual Defendants, in their personal capacities as well as their capacities as officers
of Defendant TWU Local 555, and their agents, successors, deputies, servants, and employees,
and all persons acting by, in concert with, through or under Defendants or by and through their
orders)
(a)

From calling, permitting, instigating, authorizing, encouraging, participating in,
approving of, or continuing any delay, any disruption, curtailment or restriction of
Southwest’s normal airline operations, including but not limited to strikes,
simulated strikes, picketing, work stoppages, call-outs, slowdown activity,
concerted refusals to work, concerted refusals to accept overtime and/or special
work assignments, and/or other forms of self-help, or otherwise interfering with
the operations of Southwest.

(b)

Ordering that the said Defendants and said other persons acting in concert with
them shall immediately take all reasonable steps within their power to prevent the
aforesaid actions from continuing, and to refrain from continuing the aforesaid
actions.

(c)

Ordering that the said Defendants shall immediately instruct all TWU Local 555represented ramp, operations, provisioning and freight agents employed by
Southwest to cease all premature concerted activity.

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Case 3:15-cv-03749-D Document 1 Filed 11/19/15

(d)

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Ordering that the said Defendants notify, by the most expeditious means possible,
all TWU Local 555-represented ramp, operations, provisioning and freight agents
employed by Southwest of the issuance, contents and meaning of this Injunction
Order and provide Southwest with a copy of all such notices.

(e)

Ordering that the notices described in paragraphs (c) and (d) above include a
directive from TWU Local 555 to all TWU Local 555-represented ramp,
operations, provisioning and freight agents employed by Southwest who are
engaging in the aforesaid actions to immediately cease and desist all such activity
and to immediately cease and desist all exhortations or communications
encouraging same.

(f)

Ordering that the Defendants post this Court’s Order on all TWU Local 555
bulletin boards at Southwest’s facilities and publish in all TWU Local 555
publications and include and/or transmit the contents of the ordering paragraphs
of this Court’s Order in all recorded telephone hotlines, websites or other methods
of electronic communications under control of Defendants, or any of them, and
provide a transcription of all such messages to Southwest.

(g)

Ordering that the Defendants report to the Court, by sworn affidavit, the methods
used to effect the notices described in the paragraphs above to all TWU Local
555-represented ramp, operations, provisioning and freight agents employed by
Southwest.

Southwest further prays for such other and further relief, including but not limited to
attorneys' fees and costs, as the Court may deem proper.
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Case 3:15-cv-03749-D Document 1 Filed 11/19/15

Dated: November 19, 2015

Page 15 of 15 PageID 15

Respectfully submitted,
/s Ann Marie Arcadi

Of Counsel
Kevin Minchey
(pro hac pending)
SOUTHWEST AIRLINES CO.
2702 Love Field Dr.
Dallas, TX 75235
Kevin.minchey@wnco.com

Ann Marie Arcadi
Bar No. 00786994
Michael A. Correll
Bar No. 24069537
MORGAN, LEWIS & BOCKIUS LLP
1717 Main Street, Suite 3200
Dallas, TX 75201
annmarie.arcadi@morganlewis.com
mcorrell@morganlewis.com
Tel: 1-214-466-4166
Fax: 1-214-466-4001
Thomas E. Reinert, Jr.
(pro hac pending)
Jonathan C. Fritts
(pro hac pending)
David Broderdorf
(pro hac pending)
Rachel A. Ladeau
(pro hac pending)
MORGAN, LEWIS & BOCKIUS LLP
1111 Pennsylvania Ave. N.W.
Washington, D.C. 20004
treinert@morganlewis.com
jfritts@morganlewis.com
dbroderdorf@morganlewis.com
rladeau@morganlewis.com
Tel: 202-739-3000
Fax: 1-202-739-3001

PLAINTIFF SOUTHWEST AIRLINES CO.’S ORIGINAL COMPLAINT – Page

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Case 3:15-cv-03749-D Document 1-1 Filed 11/19/15

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EXHIBIT 1

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Case 3:15-cv-03749-D Document 1-2 Filed 11/19/15

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EXHIBIT 2

Case 3:15-cv-03749-D Document 1-2 Filed 11/19/15
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TWU Local 555
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TWU Local 555 is the union for Ramp,
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Southwest Airlines.
Dallas, Texas
twu555.org

TWU Local 555 @twu_555 · Nov 12
Strike Prep #TWU555 Stay Informed! @AFLCIO @SouthwestAir
@NBCNews @abcnews @FoxNews @CBSNews @CBSNewsPress
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Case 3:15-cv-03749-D Document 1-3 Filed 11/19/15

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(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
Transport Workers Union of America, AFL-CIO, Local 555
Greg Puriski
Jerry McCrummen
Jesse Soto
Alfonso Santoyo

Southwest Airlines, Co.

Dallas County, Texas

Dallas County, Texas

(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLY)

(If Known)

(Firm Name, Address, and Telephone Number)
Morgan, Lewis & Bockius LLP
1717 Main Street, Suite 3200
Dallas, Texas 75201
214-466-4166

(Place an “X” in One Box Only)

(Place an “X” in One Box for Plaintiff
and One Box for Defendant)

(For Diversity Cases Only)

x
(U.S. Government Not a Party)

or

and
(Indicate Citizenship of Parties in Item III)

(Place an “X” in One Box Only)

x

(Place an “X” in One Box Only)

x
(specify)
(Do not cite jurisdictional statutes unless diversity)
45 U.S.C. § 151 et seq.
Unlawful job action

x
(See instructions):

11/19/2015

/s/ Ann Marie Arcadi

Case 3:15-cv-03749-D Document 1-3 Filed 11/19/15

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