We got video of the incident when it went down back in January -- after Halle and Olivier landed at LAX they were swarmed by paparazzi, and Olivier used their baby's car seat to shove the employee -- named Ronaldo Owens -- flat on his ass.
In his lawsuit, filed Monday in L.A., Owens says he wasn't blocking the couple's path ... and had every right to be where he was as an LAX employee. One angle of the video did show Owens taking a photo with what appears to be his phone.
However, in his suit Owens says Martinez brutally charged at him without provocation -- and he accuses Halle of masterminding the whole thing, saying she gave her husband "carte blanche ability to attack."
He's suing them for at least $5 million.
Owens filed a police report, but the L.A. city attorney declined to prosecute.