A special master in an antitrust case over airline passenger bag fees has recommended that Delta Air Lines pay $1.8 million in sanctions for a string of failures to turn over relevant evidence to the plaintiffs during the long-running litigation.

But Atlanta attorney Bruce Brown, in his 117-page report recommendation to the federal judge presiding over the case, did not find that Delta acted in bad faith or engaged in any willful misconduct to destroy or hide evidence that would have justified more severe penalties involving the merits of the case.