IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
Northern Division
HASSAN SADER, P.O. Box 17731, Arlington, Civil Action No.:
VA, 22216, and
COMPLAINT
THE AMERICAN ARAB ANTI-
DISCRIMINATION COMMITTEE, 4201
Connecticut Ave., N.W.; Suite 300, Washington,
D.C. 20008, on behalf of its members and
constituents,
Plaintiffs,
vs.
AMERICAN AIRLINES, INC., 4333 Amon
Carter Blvd., Fort Worth, Texas, 76155, and
AMR CORPORATION, 4333 Amon Carter
Blvd., Fort Worth, Texas, 76155,
Defendants.
Plaintiffs allege as follows:
I. NATURE OF THE CASE
Plaintiffs Hassan Sader and the American-Arab Anti-Discrimination Committee
this action seeking declaratory, injunctive, and monetary relief against Defendant American
response to the discriminatory and wholly unjustified removal of a United States citizen from an
Airlines flight, on the basis of his race and national origin, in violation of the laws of the
response to similar actions against other persons.
II. JURISDICTION AND VENUE
This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and
action for declaratory, injunctive, and monetary relief is authorized by 28 U.S.C. §§ 1343(a)(4),
2202.
Venue is proper in this District pursuant to 28 U.S.C. § 1319(b) because a
SNIPPETS:
THE AMERICAN ARAB ANTI-DISCRIMINATION COMMITTEE,
Suite 300, Washington, D.C. 20008, on behalf of its members and constituents,
Blvd., Fort Worth, Texas, 76155,
Plaintiffs Hassan Sader and the American-Arab Anti-Discrimination Committee bring
this action seeking declaratory, injunctive, and monetary relief against Defendant American
response to the discriminatory and wholly unjustified removal of a United States citizen from
Airlines flight, on the basis of his race and national origin, in violation of the laws of
discrimination against Arab and Muslim Americans, and against persons perceived to be Arab or
individuals based on their race, their religion, their national origin."
against passengers of Arab and Middle Eastern appearance have risen alarmingly.
stereotypes or attitudes or beliefs about the propensity of members of any racial, ethnic,
Notwithstanding the forceful statements of the DOT and the clear mandates of federal law,
Indeed, the DOT, which tracks consumer complaints in a monthly "Air Travel Consumer
Plaintiff Hassan Sader is a 36-year-old Arab-American citizen of Moroccan descent.
Plaintiff ADC is a non-sectarian, non-partisan, membership organization dedicated to defending
of whom, upon information and belief, also fly on American Airlines, and fly out of Baltimore
The ADC brings this action seeking declaratory and injunctive relief on behalf of
Defendant AMR Corporation is the parent company of Defendant American Airlines,
AMR Corp. is a Delaware corporation, with headquarters at 4333 Amon Carter Blvd., Fort Worth,
the gate agent who had been scanning the boarding passes came to his seat
was from the Middle East, and because his name was Hassan.
Airlines employees were attempting to accommodate the prejudices and fears of another
Inc. is liable for the unlawful acts of its agents and employees
contracts regardless of race, ancestry, or ethnicity, in violation of 42 U.S.C. § 1981.
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