The ground crew contractor that works for Spirit Airlines at Baltimore-Washington International Thurgood Marshall Airport illegally laid off about 40 workers, an employee union has alleged.

SEIU Local 32BJ is working with laid-off employees of AGI, a contractor that provides ticket counter, baggage handling and ramp work for Spirit.

In a letter to the Maryland Department of Labor on Thursday night, the union accused AGI of not providing employees or state officials with enough notice before laying off “at least” 38 people.

Maryland’s Economic Stabilization Act requires employers above a certain size to provide at least 60 days’ notice of mass layoffs to both employees and the Department of Labor.

The union accuses AGI of providing employees “at most” two weeks’ notice. The layoffs occurred between Sept. 1 and Nov. 1, according to the union. Maryland law requires the notice if the layoffs occur within a three-month period.

A spokesperson for AGI did not immediately respond to a request for comment Friday.

Tyrone Daniels, a former AGI employee, says he was given no notice before he was laid off on Oct. 27.

In an email, Daniels said he’s afraid of “starving” and lamented that the layoff happened just before Thanksgiving.

“Not having a place to go to everyday is really messing with my head,” he wrote. “I’m feeling really stuck and just want to be back at work doing what I love.”

AGI employees are not unionized, but have been working with the Service Employees International Union to call attention to workplace issues.

Employees said earlier this year that AGI had failed to protect them from extreme heat. Daniels spoke out about his working conditions with AGI in September.

Spirit Airlines is the second-biggest carrier at BWI, accounting for about 8% of its market share, according to the airport. Southwest Airlines accounts for more than 70%.