Prost v. Association of Flight Attendants
Plaintiffs, U.S. Airways flight attendants, sued the Association of Flight Attendants (AFA) and its President, Patricia A. Friend. They alleged that defendants misrepresented MidAtlantic Airways' corporate structure as a separate entity rather than a division of U.S. Airways, to deny them employment rights under their collective bargaining agreement (CBA). Plaintiffs claimed breach of fair representation under the Railway Labor Act and violations of the Racketeer Influenced and Corrupt Organization Act (RICO). The defendants moved to dismiss the complaint, arguing that the fair representation claims were time-barred and the RICO claim lacked sufficient pleading for "enterprise." The court granted the motion, dismissing the fair representation claims as time-barred (accruing in December 2002 or at latest early 2005) and the RICO claim due to a deficient pleading of the "enterprise" element.