Joseph D. Thomas v. United Parcel Service, Inc. and Local 710, International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America

Summary

The Seventh Circuit reviewed a summary judgment ruling in a hybrid § 301/fair-representation action brought by a discharged UPS employee against UPS and his union. The court addressed whether evidence of anti-dissident bias and allegedly deficient grievance handling created genuine issues of material fact concerning the union’s duty of fair representation. It vacated the summary judgment order and remanded the case to the district court.

Holdings

1. Union officials serving on a Joint Grievance Committee owe grievants a duty of fair representation, and in that adjudicatory role the duty requires fair and impartial decisions on the merits.
2. An employee must show that union conduct was arbitrary, discriminatory, or in bad faith; under the Seventh Circuit's then-governing standard, the alleged misconduct had to be intentional, invidious, and directed at the employee.
3. Summary judgment for the defendants was improper because the district court failed to consider evidence of anti-TDU bias that could support a finding that the union breached its duty of fair representation.

Questions Presented

1. Whether the district court properly granted summary judgment where evidence allegedly showed that Local 710 intentionally undermined Thomas's grievance because of his political affiliation within the union.
2. Whether union representatives serving on a Joint Grievance Committee owe grievants a duty of fair representation requiring fair and impartial decisions on the merits.
3. Whether evidence of political bias by Joint Grievance Committee members was material to Thomas's hybrid § 301/fair-representation action.

Disposition

reversed_and_remanded