Mark Pestronk Q: Our agency is in the middle of a huge debit-memo dispute with a major airline whose plate is vital to us. The airline is threatening to pull its plate if we dont pay. Is there any way to use the law to force an airline not to lift its plate?

A: As yet, there is no way to stop an airline from pulling its plate, which is industry jargon for withdrawing your right to sell tickets on that airline.

Under the ARC agreement and under general principles of agency law, the principal has the right to cease doing business with an agent at any time, for any reason, for no reason or for an invalid reason. Therefore, a court cannot compel an airline to do business with your travel agency.

However, if the travel agencies win a case scheduled to go to trial in 2005, a federal judge may effectively change the law, as he could issue an injunction barring American Airlines from threatening to lift agencies plates if they do not pay debit memos levied for back-to-back, hidden-city and throwaway ticketing.

If the case goes to trial, the agencies will need to show two key things, among others.

First, the agencies must prove they have no legal obligation to pay these debit memos, especially where they did not know that their client intended to evade the tariff rules prohibiting these types of ticketing.

The agencies should have little trouble proving this point, as American is relying on its so-called Addendum to the ARC Agent Reporting Agreement. Most travel agencies have never heard of this document, let alone read it or signed it.

Second, the agencies must prove that American has coerced them by threatening to lift its plates unless they pay the debit memos and that such coercion is a continuing phenomenon. With carefully gathered evidence, the agencies ought to be able to prove such coercion.

These proofs are part of the plaintiffs case under the federal Racketeer Influenced and Corrupt Organizations (RICO) Act.

In December, the judge heard an oral argument on Americans motion for summary judgment.

In my view, travel agencies stand a fairly good chance of winning the motion and going to trial. The case is called Westways World Travel v. AMR Corp., No. ED CV 99-386-RT(AIJx).

The same judge has already made a favorable ruling in a similar case, All World Travel v. American Airlines, 282 F. Supp. 2d 1161.

The judges opinion denying Americans motion to dismiss contains language that can already be used by every travel agency fighting plate-lifting threats.

Ill quote that language in my next column.

Mark Pestronk is a Fairfax, Va.-based attorney specializing in travel law. He answers your questions in the TravelWeekly.com Legal Ease forum. To contact Mark directly, e-mail him at [email protected].

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