On August 18, 2020, the U.S. Department of Transportation (DOT) issued a Notice of Proposed Civil Penalty against Southwest Airlines in the amount of $142 million for holiday flight disruptions that occurred during the 2022 holiday season. The DOT found that Southwest Airlines violated a provision of the Aviation and Transportation Security Act (ATSA) requiring airlines to issue refunds to customers for flight disruptions that occur rescheduled or canceled flights. In the case of Southwest Airlines, this included disruptions on twenty different occasions during the 2022 holiday season. The DOT’s investigation was initiated in response to numerous complaints from passengers who were not given refunds for flights, which were cancelled or significantly rescheduled. Through its investigation, the DOT found that Southwest Airlines had failed to promptly refund passengers for flights that were canceled or significantly rescheduled during the 2022 holiday season. In addition to the penalty, the DOT also issued a cease and desist order against Southwest Airlines, requiring the airline to take corrective actions to ensure that it does not make similar violations in the future. Southwest Airlines has agreed to pay the full penalty and comply with the DOT’s corrective action order. The DOT’s action highlights the importance of airlines providing consumers with timely and accurate refunds for canceled or significantly rescheduled flights. Airlines are legally obligated to do so under the ATSA, and as demonstrated by the DOT’s actions in this case, any violations can result in substantial fines. Airlines should take all necessary steps to ensure that passengers are given refunds when required and should ensure that all applicable legal requirements and timelines are honored.