AIR MARSHAL ASSOCIATION v. SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY

CourtDistrict Court, E.D. Pennsylvania
DecidedFebruary 4, 2025
Docket2:22-cv-02254
StatusUnknown

This text of AIR MARSHAL ASSOCIATION v. SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY (AIR MARSHAL ASSOCIATION v. SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AIR MARSHAL ASSOCIATION v. SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

AIR MARSHAL ASSOCIATION : : CIVIL ACTION v. : : NO. 22-2254 SECRETARY OF THE DEPARTMENT OF : HOMELAND SECURITY et al. :

SURRICK, J. FEBRUARY 4, 2025

MEMORANDUM

On June 6, 2022 Plaintiff Air Marshal Association (“Plaintiff” or “AMA”) filed a Complaint asserting claims against Defendants U.S. Department of Homeland Security (“DHS”), Transportation Security Administration (“TSA”), Federal Air Marshal Service (“FAMS”) (together, “Agency Defendants”), and Richard F. Altomare (collectively, “Defendants”). The Complaint alleges that Defendants engaged in retaliatory and harassing conduct that interferes with the First Amendment and contractual rights of the AMA and its members. Presently before the Court are the Agency Defendants’ and Defendant Altomare’s Motions to Dismiss. (ECF Nos. 10, 11.) For the following reasons, Defendants’ Motions to Dismiss are granted in part and denied in part. We will dismiss claims against Defendant Altomare individually due to ineffective service of process, and we will substitute the United States Government in place of Defendant Altomare with respect to the contractual interference claim. We will deny the Motions as to Plaintiff’s First Amendment and contractual interference claims (Counts I & III) to the extent the AMA seeks non- monetary relief on behalf of itself and its members against the Agency Defendants, but we will grant Defendants’ Motions to the extent Plaintiff seeks monetary damages with respect to those Counts. We will also dismiss Plaintiff’s unfair labor practices and civil conspiracy claims (Counts II & IV). I. BACKGROUND

AMA is a “labor organization” with a principal purpose of representing the interests of non-supervisory federal air marshals employed by the TSA, which is an agency within DHS. (Compl., ECF No.1, ¶¶ 4, 12.) “AMA is the sole labor organization exclusively representing Federal Air Marshals and the recognized advocate of the workgroup with respect to matters of importance to them pertaining to conditions of employment as well as constitutionally and statutorily protected benefits of their federal service.” (Id. ¶ 14.) AMA’s membership consists of more than half of current and former active-duty federal air marshals. (Id.) The Complaint alleges that “TSA management has consistently failed to work cooperatively and respectfully with the AMA and its members” and that management “interfered with the relationship between AMA and its members.” (Id. ¶ 15.) Plaintiff further alleges that

management of the Philadelphia Field Office of FAMS retaliated against members of AMA because of “whistleblower activity” and targeted members of AMA with verbal abuse, disciplinary proceedings, and other harassing behavior to weaken and diminish AMA. (Id. ¶ 16.) Plaintiff also recounts the initiation of a new policy under which “FAMs and AMA members were directed not to attempt to utilize earned sick leave or personal time for medically required appointments and/or surgeries[,]” and one instance in which two managers requested that an air marshal reschedule a cancer-related surgery. (Compl. ¶ 17.) Plaintiff claims that it submitted numerous letters to FAMS and TSA management regarding these issues and other grievances, which were ignored. (Id. at ¶¶ 18-26.) One letter chronicled how “individual FAMs, primarily AMA members, had their performance evaluations intentionally and artificially lowered and adjusted down.” (Id. ¶ 20.) Another letter noted that “selective targeting of AMA members had been allowed to continue without proper redress” and “pointed out specific examples of AMA members being targeted.” (Id. ¶ 21.)

Plaintiff claims that TSA and FAMS officials, including Defendant Altomare, ignored letters and requests for information from AMA and its lawyers regarding a wide range of grievances. (Id. ¶¶ 18-26.) AMA asserts claims on behalf of itself and its members for violations of the First Amendment (Count I), Unfair Labor Practices (Count II), Intentional Interference with Contractual Relations (Count III), and Civil Conspiracy (Count IV). AMA seeks injunctive and declaratory relief (in Counts V & VI, respectively), as well as monetary damages. II. LEGAL STANDARD A. Fed. R. Civ. P. 12(b)(1): Lack of Subject-Matter Jurisdiction To adjudicate a case, a federal court must have subject matter jurisdiction. See Bender v. Williamsport Area Sch. Dist., 475 U.S. 534, 541-42 (1986). A court must grant a motion to dismiss

if it lacks subject matter jurisdiction over the case. Fed. R. Civ. P. 12(b)(1). The party asserting that jurisdiction is proper bears the burden of showing that jurisdiction exists. Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). In evaluating a Rule 12(b)(1) motion, a court must first determine whether the movant presents a factual or facial attack. In re Schering Plough Corp. Intron/Temodar Consumer Class Action, 678 F.3d 235, 243 (3d Cir. 2012). “A factual attack ... is an argument that there is no subject matter jurisdiction because the facts of the case ... do not support the asserted jurisdiction.” Const. Party of Pennsylvania v. Aichele, 757 F.3d 347, 358 (3d Cir. 2014). On a factual attack, the “court may weigh and consider evidence outside the pleadings.” Const. Party of Pennsylvania, 757 F.3d at 358 (quoting Gould Elecs. Inc v. United States, 220 F.3d 169, 176 (3d Cir. 2000)). A facial challenge “contests the sufficiency of the pleadings” and the court “must only consider the allegations of the complaint and documents referenced therein and attached thereto, in the light most favorable to the plaintiff.” In re Schering Plough Corp., 678 F.3d at 243 (quoting Gould

Elec. Inc., 220 F.3d at 176). B. Fed. R. Civ. P. 12(b)(6): Failure to State a Claim Upon Which Relief Can be Granted.

“[A] plaintiff must allege ‘enough facts to state a claim to relief that is plausible on its face’” to survive a motion to dismiss pursuant to Rule 12(b)(6). New Jersey Carpenters & the Trustees Thereof v. Tishman Const. Corp. of New Jersey, 760 F.3d 297, 302 (3d Cir. 2014) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A complaint has facial plausibility when there is enough factual content ‘that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.’” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). When considering the sufficiency of a complaint on a 12(b)(6) motion, a court “must accept all factual allegations in the complaint as true and draw all reasonable inferences in favor of the plaintiff.” Id. (citing Phillips v. Cnty. of Allegheny, 515 F.3d 224, 231 (3d Cir. 2008)). The court should also consider the exhibits attached to the complaint and matters of public record. See Schmidt v. Skolas, 770 F.3d 241, 249 (3d Cir. 2014). A complaint that merely alleges entitlement to relief, without alleging facts that show such an entitlement, must be dismissed. See Fowler v. UPMC Shadyside, 578 F.3d 203, 211 (3d Cir. 2009).

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AIR MARSHAL ASSOCIATION v. SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/air-marshal-association-v-secretary-of-the-department-of-homeland-security-paed-2025.