“Several times since August 30, 2021, Southwest Airlines has taken new unilateral actions which violate the status quo between the parties in further violation of the Railway Labor Act. Most recently, on October 4, 2021, Southwest Airlines unilaterally rolled out a new and non- negotiated COVID vaccine mandate for all employees, including SWAPA pilots. The new vaccine mandate unlawfully imposes new conditions of employment and the new policy threatens termination of any pilot not fully vaccinated by December 8, 2021. Southwest Airlines’ additional new and unilateral modification of the parties’ collective bargaining agreement is in clear violation of the RLA. Because of Southwest Airlines’ continued unilateral actions, and its continued violations of the RLA which harm SWAPA and its members, this motion is necessary and SWAPA respectfully seeks an immediate hearing.”

https://storage.courtlistener.com/recap/gov.uscourts.txnd.352616/gov.uscourts.txnd.352616.11.0.pdf