Fifth Circuit Reverses Sanctions Mandating Religious Training for Southwest Lawyers
The Fifth Circuit reversed sanctions requiring Southwest Airlines' lawyers to complete religious liberty training.
Why it matters: This ruling clarifies limits on courts imposing sanctions tied to lawyers' personal beliefs, impacting how legal teams address workplace discrimination cases and uphold constitutional rights.
- On June 8, 2026, Judge Brantley Starr dropped further contempt actions after the Fifth Circuit overturned the sanctions.
- Three Southwest Airlines attorneys were ordered to attend religious liberty training by the Alliance Defending Freedom before the reversal.
- The Fifth Circuit ruled the sanctions were punitive (intended as punishment) rather than remedial (meant to enforce compliance), exceeding judicial authority.
- Charlene Carter, a former flight attendant, was awarded nearly $946,103 for violations of labor and civil rights laws including Title VII (which prohibits workplace discrimination).
The dispute began when Charlene Carter, a Southwest Airlines flight attendant, was terminated after expressing pro-life views and criticizing her union's support for a pro-abortion event. A jury found that Southwest and the Transport Workers Union infringed her rights under the Railway Labor Act and Title VII of the Civil Rights Act of 1964, which prohibits workplace discrimination. Carter was awarded $946,103 in damages.
Following the verdict, U.S. District Judge Brantley Starr imposed sanctions on three Southwest attorneys, requiring them to attend religious liberty training conducted by the Alliance Defending Freedom (ADF), a conservative legal group. The order aimed to address perceived misconduct by the lawyers.
On June 8, 2026, after the Fifth Circuit's published opinion, Judge Starr announced he would not pursue further civil or criminal contempt actions related to the sanctions. The appellate court found the sanctions punished the lawyers personally rather than compelling Southwest's compliance, thus exceeding the court's remedial powers.
The Fifth Circuit clarified that sanctions must either enforce a court's orders or remedy misconduct directly related to litigation conduct. Punitive measures, such as mandated religious training tied to personal beliefs, overstep judicial authority and risk infringing constitutional protections.
Carter described her job as her livelihood and passion, criticizing union and employer actions as retaliatory for her sincerely held religious beliefs. This case underscores the careful balance courts must maintain when considering sanctions implicating personal and religious freedoms.
Legal professionals should note this precedent limits courts’ ability to impose sanctions requiring ideological or belief-based training. It reinforces the necessity of distinguishing between remedial sanctions that ensure compliance and punitive sanctions that could violate lawyers’ constitutional rights.
For further details, the Fifth Circuit's full court opinion provides legal reasoning and analysis.
By the numbers:
- $946,103 — damages awarded to Charlene Carter for discrimination violations
- June 8, 2026 — date Judge Starr ceased contempt proceedings after appellate reversal
- Three — number of Southwest attorneys originally sanctioned to attend religious training
Yes, but: While the Fifth Circuit ruled the sanctions punitive and improper, courts retain authority to impose remedial sanctions that directly enforce compliance or address litigation misconduct without infringing personal belief protections.
What's next: Legal teams should monitor potential lower court responses to this ruling and any legislative or policy changes affecting sanctions and workplace religious expression.