Former UFC women’s bantamweight Leslie Smith today filed a complaint against UFC parent company Zuffa for unfair labor practices, alleging the fight promotion effectively terminated her employment to retaliate against her efforts with Project Spearhead.

In a 12-page complaint penned by Project Spearhead legal consultant Lucas Middlebrook, the complaint claims Zuffa cut Smith (10-7-1 MMA, 4-3 UFC) “based on the animus it held toward her engagement in protected activity” while also sending an anti-union message to other fighters.

“Dare to form, join or assist a union and you too will accompany Ms. Smith not fighting in the UFC,” Middlebrook wrote. “This message contravenes the very purpose of the (National Labor Relations Act) and ZUFFA cannot be allowed to continue flouting the Act. No person or entity is above the law.”

The complaint, obtained by MMAjunkie and viewable here, was filed with the National Labor Relations Board, which enforces U.S. labor law on collective bargaining and unfair labor practices. Smith, 35, promised to hold the UFC to account after she was essentially bought out of her contract prior to UFC Fight Night 128.

Middlebrook alleges Zuffa violated Sections 8(a)(1) and 8(a)(3) of the National Labor Relations Act, which protects workers from retaliation for engaging in unionizing activities. UFC reps did not immediately respond to requests for comment; MMAjunkie will update the story with any response received.

One day prior to UFC Fight Night 128, Smith was paid her show and win money for a scheduled fight with Aspen Ladd (6-0 MMA, 1-0 UFC) and then fully released from her contract, despite the fact that Ladd missed weight and the the promotion canceled the bout.

In an interview with MMAjunkie, Smith, who was on the last fight of her contract, believed she would receive her full show and win money per the rules of the New Jersey State Athletic Control Board, which regulated the event.

Still, Smith hoped to use Ladd’s miss at the scale to leverage a new deal for herself, one that would pay a flat $100,000 per appearance for two additional bouts. When the UFC balked at that number, she offered her previous rate and agreed to fight Ladd.

When the UFC again demurred, Smith then considered taking the fight without a new deal, but decided against it based on her work with Project Spearhead, which aims to get 30 percent of the UFC’s roster to sign union authorization cards that will help determine whether fighters are independent contractors or employees.

Throughout Smith’s complaint, she is referred to as an employee, which runs contrary to the independent contractor status Zuffa applies to its fighters. Middlebrook claims Zuffa is a statutory employer of fighters and added an additional complaint could be filed against the promotion for misclassifying them.

Middlebrook noted Smith’s role as Project Spearhead’s interim president and her organizing activities, citing the 350 tweets she sent out urging fighters to sign authorization cards and media appearances she did in support of the project. He also claims Zuffa was aware of her activities through a meeting she requested in Las Vegas.

This past December, he wrote, Smith sought to clarify new promotional guidelines issued by the UFC and set up a meeting with UFC executive Reed Harris, who then no-showed a meeting at the promotion’s offices. Smith was then contacted by UFC Chief Counsel Hunter Campbell, who agreed to meet with her only to be unavailable when she attempted to set up the meeting.

Smith’s role could be no clearer, argued Middlebrook, when she sent Zuffa a picture of the mouthpiece she planned to use for the bout against Ladd, which had a Project Spearhead logo on it.

Middlebrook claims Campbell played a central part in the refusal to renew Smith’s contract.

In a previous interview with MMAjunkie, Middlebrook predicted Smith’s case could force the issue of determining whether UFC fighters are independent contractors or employees.

But in the meantime, Middlebrook and Smith are hoping to get justice for what happened before UFC Fight Night 128.

“There simply can be no dispute ZUFFA took adverse action against Ms. Smith, and based on the facts set forth herein and those to be uncovered in the investigation into this issue, ZUFFA’s animus toward Ms. Smith’s protected activity was the substantial or motivating reason for the adverse action(s) taken against her,” he wrote.

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