One Agent's Fight: Sarah Hall, plaintiff, proves no soft touch

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t was like a scene out of a movie. A cadre of federal marshals swarmed the posh Sheraton Bal Harbor Hotel in Miami. They sought out 12 IATA members and participants who had gathered there two weeks ago for the airline trade group's 25th annual Passenger Agency Conference. And, finally, in a moment of high drama, the marshals served them with subpoenas, requiring them to provide depositions on Aug. 6.

Aside from being what was easily one of most unusual moments at this or any other IATA meeting, the incident was the latest twist in what may be one of the most significant lawsuits ever initiated by an agent against the airlines.

The agent is Sarah Hall, the owner of an 8-year-old agency in Wilmington, N.C., called Travel Specialist. Supporting her position are her attorneys, Anderson Daniel & Coxe, a firm that specializes in medical malpractice. And behind them are antitrust experts and yet more attorneys.

During an interview with Travel Weekly, Hall and her attorneys offered a broad overview of the case, but they could not discuss certain aspects, such as the content of depositions taken from airline executives or a six-hour deposition that Hall provided.

The suit, slated to go to trial on April 23, in many ways covers some of the same ground as the commission caps class action that agents settled out of court with the airlines in 1997. But Hall's attorneys feel they have the benefit of something the lawyers on the last case didn't: history.

"The factual basis on which we rely was not developed significantly at that time," said Henry "Andy" Anderson, senior partner at Anderson Daniel & Coxe, and a long-time client of Hall's agency.

But since then, Anderson contends the airlines, through several matched commission cuts and the development of airline-owned Web site Orbitz, have been engaged in a clearly defined pattern of anticompetitive behavior.

Furthermore, added A.L. Butler Daniel, another partner in the firm, "This time around, you have a more tenacious team than you did the last time. And we are not going away."

The wrong woman

"Sarah feels this case," Anderson said. "She's not going to give up. [The airlines] got the wrong woman upset."

The suit, which Hall's attorneys have petitioned the courts to certify as a class action, has come a long way from Oct. 8, 1999, the day Hall received a fax from United Airlines saying it was cutting agent commissions from 8% to 5%. Soon after, other major airlines followed.

"I felt, 'How can they do this? How can they do this to us? They are basically killing us all at one time,' " Hall said.

"We are putting people on their airlines," she said. "We are encouraging people to take vacations. At times, I just don't know what the method to their madness is."

Hall felt she had no recourse other than to sue. But the first lawyer she approached wasn't interested.

He "felt that there was a lot involved in terms of time and money," said Hall.

However, Hall, who always makes time to attend her weekly kickboxing class, is not exactly the type of person who runs from trouble.

That was the case in 1994 when she was about to fulfill her long-held dream of opening her own agency.

It almost didn't happen.

"The signage cost $5,000, and I didn't have the money to pay for it," Hall said.

But true to form, Hall, a wife and mother with two sons (one 19 years old, the other 4), buckled down and decided to open it anyway.

"I didn't take out any loans," said Hall. "I pretty much went in, did it full force by myself and did what I had to do."

Today, Hall's agency employs five agents and works with three outside agents.

"They all did it?"

Not surprisingly then, one uninterested lawyer was not enough to dissuade her from pursuing the lawsuit.

After the United commission cut, Hall mentioned her situation to a friend who worked for Anderson's law firm, located in nearby Wrightsville Beach.

That led to a meeting with one of the firm's partners, Bradley Coxe, who looked at Hall's agent contract with United. He felt the terms of the contract clearly stated the airline, at its discretion, could alter its commissions.

Coxe recalls that he advised Hall to sell other airlines, but she said, "I can't," because all of the airlines had cut commissions.

Coxe replied, "What do you mean -- they all did it?"

After reviewing a chronology of events and other data, it didn't take the lawyers at the firm long to conclude that, "this looked like an antitrust case," Coxe said.

In December 1999, they filed suit in the U.S. District Court of North Carolina against a slew of U.S. and foreign airlines -- American, United, Delta, Northwest, Continental, US Airways, TWA, AirTran, America West, Frontier, Midwest Express, Alaska, Horizon, Air France, KLM, Lufthansa, Alitalia and Air Canada -- alleging unfair competition and restraint of trade.

In addition to the subpoenas served at the IATA meeting in Miami, Hall and her attorneys have filed in courts in Canada and Switzerland to obtain, among other things, "all minutes and attendance records and transcripts, audio tape recordings, memorandum, letters ... all electronic/computer generated data," such as e-mails and agendas of previous IATA meetings.

After poring over boxes of documents extracted from the airlines, Hall and her attorneys said they are convinced that the recordings and other transmissions contain one or possibly several conversations among certain airline executives who discussed cutting travel agent commissions.

Overall, the suit alleges that the carriers are involved in signaling, engaging in a consistent pattern of parallel conduct to destroy travel agencies and using Internet fares to discriminate against the use of agents. It also encompasses the cut to zero commissions last March by the major airlines.

To underscore the impact of Hall's allegations to the larger agent community, ARTA and three other agencies have signed on as co-plaintiffs: Travel Management Professionals in Miami; Peoples Travel Limited in Belleville, Mich.; and Flowers Travel at Scotts Air Force Base, Ill.

Key ruling

The case got a significant boost earlier this year when the presiding judge, W. Earl Britt, ruled against the airlines' motion to strike certain portions of the Hall complaint. He maintained that the "plaintiff's complaint pleads facts that are sufficient to support the existence of consciously parallel behavior" by the airlines.

Hall's attorneys said Britt's ruling was an important victory for Hall.

"Once you have conscious parallelism, which we have here, then you have put in what we call plus factors," said Anderson. "The plus factors, are things like motives to conspire. They had to have a reason, an opportunity ... high levels of inter-firm communications. Irrational acts are acts contrary to a defendant's economic interests but rational if the alleged agreement existed."

Anderson said the airlines have a right to set prices.

"It is the American way. It is called capitalism," he said.

With a glint in his eye, he shifts in his chair and leans forward to emphasize his point.

"But price-fixing is illegal," he said.

And with a court date less than a year away and the IATA deposition in a few weeks, Hall and her attorneys appeared raring to go.

"We are taking these guys down to the mat," Anderson said.

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