OFFICE OF THE ELECTION SUPERVISOR
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
IN RE: JACQUELINE VARGAS ) Protest Decision 2025, ESD 3
Protestor. ) OES Case No. P-002-080625-SO &
)
INTRODUCTION
Jacqueline Vargas, member of Local 391, has filed two pre-election protests pursuant to Article XIII, Section 2(b) of the Rules for the 2025-2026 IBT International Union Delegate and Officer Election (“Rules”). The first protest, P-002-080625-SO (“P-002”), alleges that Local 391 Business Agents Michael Bentley and Chris Vaughn violated Article VII, Section 12(a)-(c) by engaging in campaign activities during work time and with improper use of union funds and resources. The second protest, P-006-080925-SO (“P-006”), alleges that Mr. Bentley subsequently retaliated against Ms. Vargas after she filed P-002 by removing her as an administrator on the Teamsters for Carolinas (unofficially) Facebook group in violation of Article VII, 12(g) & (c). These protests were consolidated for investigation and decision.
Office of the Election Supervisor Regional Director Dolores Hall investigated this protest.
FINDINGS OF FACT
P-002 – Petition and Membership Drive at the UPS Greensboro Facility on August 4, 2025
Around the week of July 28, 2025, Willie Ford, President of Local 71 and member of the Teamsters United 2026 slate, contacted Mr. Bentley about conducting a petition drive to collect signatures from members in connection with the IBT International Union Delegate and Officer Election at the UPS Greensboro facility. Mr. Bentley stated that prior to Mr. Ford contacting him, he had planned to have a membership drive to collect applications for membership in the local at that facility but had not due to the weather.[1] After the call with Mr. Ford, Mr. Bentley set up a membership drive at the UPS Greensboro facility for Monday August 4, 2025—the same day as Mr. Ford’s petition drive. Mr. Bentley sent at least two text messages asking if any stewards were interested in helping out at the facility on August 4th. He also sent out a message on a Facebook group named, “Teamsters of the Carolinas (unofficially)” announcing that Mr. Ford would be at the UPS Greensboro facility on August 4th campaigning for pledge cards and encouraged people to stop by the tables to pledge their commitments to the Teamsters United 2026 slate. The posting included a picture of an O’Brien Zuckerman Teamsters United 2026 Slate Endorsement flyer depicting Ford and announcing his visit. Mr. Ford stated that he did not know a membership drive was scheduled at the UPS Greensboro facility at the same time he was planning to collect signatures for the petition until he arrived at the facility that day. There is no evidence that Mr. Ford or the Teamsters United 2026 slate instructed or was aware of Mr. Bentley’s postings in the Facebook group.
On August 4, 2025, Mr. Bentley drove a Local 391 truck, carrying a Local 391 canopy, tables, chairs and various IBT and Local 391 swag to the Greensboro UPS facility and set up for the membership drive. Mr. Vaughn subsequently arrived with biscuits, water, and Gatorade to distribute at the event. These were purchased with Local 391 funds. Use of these resources is typical for a Local 391 membership drive in the parking lots of UPS facilities.
Mr. Ford and Brandon Price, Secretary-Treasurer and Business Agent for Local 71, arrived at the Greensboro UPS facility with their own table. When they arrived, Mr. Bentley told them that they had a table for Mr. Ford to use and Mr. Ford placed his table back inside his vehicle and did not use it during the event. Mr. Ford and Mr. Price also brought clipboards and petitions for the Teamsters United 2026 slate.
The membership drive and petition drive lasted from approximately 7:30 AM through 6:00 PM. Throughout the petition drive, Mr. Ford and Mr. Price solicited signatures for the Teamsters United 2026 slate. Mr. Vaughn acknowledged that both he and Mr. Bentley were on scheduled working time for Local 391, and solicited signatures for the Teamsters United 2026 petitions. In total, approximately 400 signatures were collected during the event. Following the event, Mr. Bentley posted comments about and photographs of the event to the Facebook group “Teamsters of the Carolinas (unofficially).” These photographs show individuals gathered around a table with the Local 391 canopy including some who appear to be signing something. Mr. Ford is in at least two of the photographs including one, where an individual in a UPS uniform is signing a document on a clipboard.[2]
Unsure of whether the activities of August 4, 2025 at the Greensboro UPS facility were consistent with the Rules, Mr. Ford kept the signatures collected from this petition drive isolated from others. After Ms. Vargas filed P-002, Mr. Ford, through counsel for the Teamsters United 2026 slate, proactively reached out to the Office of the Election Supervisor, did not oppose or defend the actions set forth above and immediately agreed to collect those signatures and not use them for purposes of establishing accredited candidate status. They also sent the original signatures to the OES.
P-006 – Teamsters of the Carolinas (unofficially) Facebook Group
Three days following the filing of P-002, Ms. Vargas filed P-006 alleging that Mr. Bentley retaliated against her for filing P-002 by removing her as an administrator on a Facebook group and making the group private, thus not searchable for her. Following the filings of P-006, Mr. Bentley blocked Ms. Vargas from the Facebook group.
On May 5, 2023, Mr. Bentley created a Facebook group, called “Teamsters of NC (unofficial).” On July 8, 2025, the name of the Group was changed from “Teamsters of NC (unofficial)” to “Teamsters of the Carolinas (unofficially)” because Local 509 in Greenville, South Carolina, joined the Group. Now, Teamsters of the Carolinas (unofficially) is available to members of Local 391, 61, 71 and 509. This Facebook group is referred to herein as the “Group.” Mr. Bentley stated that he created the Group to keep members, mostly UPS employees, apprised of the general ongoings and issues related to various crafts within the IBT members in the Carolinas. Mr. Bentley created the Group as private and hidden meaning that only people who are invited and approved as a member of the Group can post to the Group and view the posts by other members in the Group. Contrary to Ms. Vargas’s allegations, the group was private prior to her removal as an administrator. Otherwise, it is not visible to the public and cannot be found through a search on Facebook to nonmembers or accessed through a direct link. It is only searchable, visible, and accessible to people granted access. Individuals invited to the Group are vetted by the administrators, who are given certain permissions that allow them to approve new members and monitor the content of the Group. There are currently three administrators, Mr. Bentley and two other individuals.
As of this investigation, the group remains private and hidden.[3] Based on screenshots of the Facebook Group provided as part of P-006, the image used to represent the Group depicts the Local 391 logo overlaid with the OZ Teamsters United logo in a stylized shape of North and South Carolina. In the “About” section of the Group, it states:
A page composed of Teamsters across the Carolinas to help keep people informed and up to date on information that affects members in their craft. Where Teamster members can openly and freely discuss things that matter to them. Open to members of Local 391, 61, 71, and 509.[4] This is not an official page of any local and we bear the right to allow or not allow participation of individuals given this is a private group. Only members can see who’s in the group and what they post. (emphasis added).
ANALYSIS
While all union members have the right to participate in campaign activities, Article VII, Section 12(a) of the Rules prohibits any candidate or member from campaigning during his or her work hours. Article VII, Sections 12(b) also prohibits union officers and employees from participating in campaign activities involving the expenditure of union funds including, but not limited to, campaigning on time paid for by the union. Officers and employers are permitted to endorse a candidate but solely in his or her individual capacity. Id. A local union is prohibited from endorsing or otherwise advancing a candidacy. Id. Article VII, Section 12(c) prohibits the use of union funds, equipment and other resources to assist with campaigning unless the union is reimbursed at fair market value and all candidates are provided equal access and notified in writing in advance. Union officers and employees provided with a union vehicle who have the right to use the vehicle for personal activities, may use the vehicle for campaign activities provided no costs or expenses incurred as a consequence of such use are paid out of union funds or other prohibited sources. Article XI, Section 12(g) prohibits retaliation against any member for exercising any of their rights under the Rules.
Mr. Bentley and Mr. Vaughn, violated Article VII, Sections 12(a)-(c) of the Rules. Specifically, Mr. Bentley’s use of Local 391’s resources and equipment including, a truck, canopy, and tables to further the campaign of the Teamsters United 2026 slate was a violation of the Rules. Similarly, Mr. Vaughn’s use of Local 391’s funds to purchase the food and beverages distributed at the event was also a violation. Additionally, Mr. Bentley and Mr. Vaughn violated the Rules by engaging in campaign activities during work time.
As for the retaliation allegations related to the Facebook group Teamsters of the Carolinas (unofficially), we find Brotherhood of Maintenance of Way Employes Division, 2016 ESD 299 (October 7, 2016) instructive. In Brotherhood of Maintenance of Way Employes Division, 2016 ESD 299 (October 7, 2016), a Facebook page closed to the public, owned and administered by a member[5] but titled, Brotherhood of Maintenance of Way Employees BMWED (Members Forum – UNOFFICIAL) posted and promoted Teamsters United candidates while disparaging Hoffa-Hall 2016 candidates. The Brotherhood of Maintenance of Way Employes Division (or BMWED) filed a protest alleging the Facebook page violated the Rules by misrepresenting itself as the BMWED labor organization to present partisan campaign material and impermissibly used content appropriated from official BWMED material. The Election Supervisor explained:
The analytical framework the Rules provides for assessing this protest starts with Article VII, Section 12(c), which broadly prohibits use of union facilities “to assist in campaigning.” Further, Article VII, Sections 8 and 9 bar use of a “publication or communication financed, sponsored or used, directly or indirectly, by a Union (including a social media site) … to support or attack any candidate or the candidacy of any person.” Definition 5(f) declares that “campaign contribution” includes “[a]n endorsement or counter-endorsement by an individual, group of individuals, or entity.” These provisions establish that a union is prohibited from endorsing a candidate. Leedham Slate, 2006 ESD 380 (October 26, 2006). But moreover, an individual or group of individuals is prohibited from representing that a union has endorsed a candidate, even if the union itself has not made what would be a prohibited endorsement. Rivers, 2011 ESD 137 (February 24, 2011) (candidate’s claim that the union “backs” his candidacy violated the Rules); Collins & Strohl, 2011 ESD 143 (March 2, 2011) (candidate impermissibly appropriated a prohibited union endorsement with a flyer to the local union membership that did not identify the sender but listed the “International Brotherhood of Teamsters” as the return address, giving the impression that the IBT had mailed the campaign flyer to local union members). A candidate or a candidate’s supporters can avoid appropriating an improper union endorsement in a social media context by demonstrating clearly that the social media page is not sponsored or authorized by the union. Hoffa-Hall 2016, 2015 ESD 41 (October 16, 2015) (a Facebook page that was designated an unofficial members’ forum and included a disclaimer that the page was not published or sponsored by a labor organization was found not to violate the Rules).
Although Mr. Bentley includes the Local 391 logo on the Group Facebook page, the name of the Group clearly states that it is not an official group sponsored by any local and the description of the Group includes a disclaimer clearly articulating the same. Thus, members of the Group are clearly notified that it is not an official Facebook group for the local. Additionally, because the Group is private and hidden, meaning non-members cannot see the Facebook Group, non-members cannot be misled by the use of the Local 391 logo.
Mr. Bentley admitted that he removed Ms. Vargas as an administrator of the Group and blocked her because of the protests she filed against him. Ms. Vargas has the right to file a protest concerning alleged violations of the Rules without the fear of retaliation for doing so under Art., XIII, Section 1 but she does not have a legal right to participate in a private Facebook group created by another. Precedent demonstrates that the Rules protect a broad right of free association under Article VII, Section 12(a) and members have the right to associate with like-minded members and exclude others if they so choose. In Konowe, P-008-LU632-NYC (October 29, 1990), aff’d, 90 Elec. App. 8 (November 7, 1990), the Election Officer held that individuals required to leave a TDU meeting had no claim to a Rules violation:
It is not a violation of the Election Rules for a campaign organization or member caucus to limit attendance or participation in their meetings to individuals who share their beliefs or objectives. The fact that the leaflet advertising the TDU meeting in question stated that the meeting was open to all Local 732 members, and that the Konowe protestors were members of Local 732, does not restrict the right of TDU to ask the Konowe protestors and other Local 732 officials to leave.
This holding has been followed in subsequent supervised International Officer Elections. In 1996, the Election Officer concluded that “members gathered for [a] TDU meeting had a right under the Rules to limit their meeting to individuals who shared their electoral beliefs or objectives. ‘If a member or candidate does not wish to associate with another member or candidate…, various sections of the Rules protect that wish.’ Baudo, P-680-LU344-SCE (April 3, 1996), aff’d, 96 Elec.App. 165 (KC) (April 12, 1996). Freedom of association is a fundamental political right included in Article VIII, Section 11(a)’s basic guarantee: ‘All union members retain the right to participate in campaign activities…’[6] Thus, with respect to the International officer election, members have the right to associate with like-minded members and to exclude others if they choose.” Rudolph, P-861-TDU-PNW (August 29, 1996); see also Richards, 2000 EAD 27 (September 27, 2000), aff’d, 00 EAM 8 (October 23, 2000); see also Zuckerman, 2015 ESD 7 (July 15, 2015) (affirming this right in the 2016 election cycle).
While the facts of this case are distinguishable, we do not see a compelling reason not to extend this right of association to private Facebook groups under circumstances similar to those presented here. Mr. Bentley, as creator and administrator, is permitted to vet potential members, block, and change administrators to his private group. Although his conduct was spiteful and vindictive, we find that is does not rise to the level of conduct contemplated by the Rules to ensure a fair and open election. See e.g., Stefanski, P282 (January 22, 1996), aff'd 96 EAM 94 (February 21, 1996) (vile and threatening language accompanied by physical grabbing violates the Rules); Smith, P600 (April 30, 1996) (holding “I'll kill you” to violate Rules); Sandy Pope, 2011 ESD 325 (Sept. 15, 2011) (repeated conduct by the principal officer in an effort to intimidate members and interfere with their protected rights to engage in campaign activity was a violation of the Rules).
CONCLUSION
For the reasons set forth above, we find that there is sufficient evidence Mr. Bentley and Mr. Vaughn violated Article VII, Sections 12(a)-(c) of the Rules and P-002 is granted. We do not find that the Facebook group Teamsters of the Carolinas (unofficially) is an official group publishing official statements of a local and find no violation of Article VII, Sections 8 or 9 prohibiting the use of union publications (including union-sponsored social media) to campaign. Further, we do not find that Mr. Bentley’s removal of Ms. Vargas from a private Facebook group violated the Rules.
REMEDY
When the Election Supervisor determines that the Rules have been violated, he “may take whatever remedial action is deemed appropriate.” Article XIII, Section 4. In fashioning the appropriate remedy, the Election Supervisor views the nature and seriousness of the violation as well as its potential for interfering with the election process. “The Election Supervisor’s discretion in fashioning an appropriate remedy is broad and is entitled to deference.” Hailstone & Martinez, 10 EAM 7 (September 14, 2010).
Since P-002 was filed, both Mr. Bentley and Mr. Vaughn have each taken a vacation day for August 4, 2025, Mr. Vaughn reimbursed Local 391 $300 for the food and beverages for the event,[7] and Mr. Ford and the Teamsters United 2026 slate have forfeited all of the signatures collected at the event. However, we hereby order Mr. Bentley and Mr. Vaughn to cease and desist from any further violations of the Rules and to post, or cause to be posted, the first notice attached to this decision on all union bulletin boards under Local 391’s jurisdiction and maintain that posting for 30 days to advise members that such conduct is a violation of the Rules and will not be tolerated. The notice shall be posted no later than two working days after the issuance of this decision; within three working days thereafter, Mr. Bentley and Mr. Vaughn shall submit an affidavit of compliance affirming that such notice has been posted to the OES. The purpose of this notice is to educate members of Local 391 of the Rules’ requirements, notify them that Mr. Bentley and Mr. Vaughn’s conduct was a violation of the Rules, and to provide a deterrent from other misuse of union resources to campaign.
We further order Mr. Bentley to remove photographs of the event on August 4th because it was conducted in violation of the Rules from and to post the second notice attached to this decision on the Facebook Group Teamsters of the Carolinas (unofficially) under the heading, “A notice ordered posted by the Election Supervisor for the International Brotherhood of Teamsters” within two working days after the issuance of this decision. He must also provide proof of his compliance with this posting by the same date. This Facebook Group includes members not only from Local 391 but also Locals 71, 61 and 509. The purpose of this remedy is to provide notice to members outside of Local 391 with access to the Group including the content therein concerning the April 4th event, of Mr. Bentley and Mr. Vaughn’s violations of the Rules in connection with that event.[8]
Any interested party not satisfied with this determination may request a hearing before the Election Appeals Master within two (2) working days of receipt of this decision. Any party requesting a hearing must comply with the requirements of Article XIII, Section 2(i). All parties are reminded that, absent extraordinary circumstances, no party may rely in any such appeal upon evidence that was not presented to the Office of the Election Supervisor. Requests for a hearing shall be made in writing, shall specify the basis for the appeal, and shall be served upon:
Barbara Jones
Election Appeals Master
IBTappealsmaster@bracewell.com
Copies of the request for hearing must be served upon the parties, as well as upon the Election Supervisor for the International Brotherhood of Teamsters, all within the time prescribed above. Service may be accomplished by email, using the “reply all” function on the email by which the party received this decision. A copy of the protest must accompany the request for hearing.
Timothy S. Hillman
Election Supervisor
Cc: Barbara Jones
2025 ESD 3
DISTRIBUTION LIST (BY EMAIL UNLESS NOTED OTHERWISE):
Jacquelyn Vargas
Michael Bentley
mbentley@teamsterslocal391.org
Chris Vaughn
David Suetholz
Edward M. Gleason, Jr.,
Richard Hooker
Will Bloom,
Ken Paff
Thomas Kokalas
Timothy S. Hillman
Paul Dever
Dolores Hall
Felicia Hardesty
Kelly Hogan
OFFICE OF THE ELECTION SUPERVISOR
for the INTERNATIONAL BROTHERHOOD OF TEAMSTERS
1750 K STREET, N.W., SUITE 200
WASHINGTON, D.C. 20006
844-428-8683 TOLL FREE
FAX: 202-807-1074
electionsupervisor@ibtvote.org
Hon. Timothy S. Hillman
Election Supervisor
NOTICE TO MEMBERS OF TEAMSTERS LOCAL 391
Article VII, Section 12(a) of the Rules for the 2025-2026 IBT International Union Delegate and Officer Election (“Rules”) prohibits any candidate or member from campaigning during his or her work hours. Article VII, Sections 12(b) also prohibits union officers and employees from participating in campaign activities involving the expenditure of union funds including, but not limited to, campaigning on time paid for by the union. Officers and employers are permitted to endorse a candidate but solely in his or her individual capacity. Id. A local union is prohibited from endorsing or otherwise advancing a candidacy. Id. Article VII, Section 12(c) prohibits the use of union funds, equipment and other resources to assist with campaigning unless the union is reimbursed at fair market value, and all candidates are provided equal access and notified in writing in advance. Union officers and employees provided with a union vehicle who have the right to use the vehicle for personal activities, may use the vehicle for campaign activities provided no costs or expenses incurred as a consequence of such use are paid out of union funds or other prohibited sources. Article XI, Section 12(g) prohibits retaliation against any member for exercising any of their rights under the Rules.
The Election Supervisor found that Michael Bentley and Chris Vaughn violated Article VII, Sections 12(a)-(c) of the Rules in connection with an event on April 4, 2025 at the UPS Greensboro facility involving a petition drive by a member of the Teamsters United 2026 slate to collect signatures from members in connection with the IBT International Union Delegate and Officer Election and a membership drive to collect applications for membership in Local 391. Specifically, Mr. Bentley’s use of Local 391’s resources and equipment including, a truck, canopy, and tables to further the campaign of the Teamsters United 2026 slate and Mr. Vaughn’s use of Local 391’s funds to purchase the food and beverages for the event violated the Rules. Additionally, Mr. Bentley and Mr. Vaughn participation in campaign activities during work time violated the Rules.
Mr. Bentley and Mr. Vaughn have each taken a vacation day for August 4, 2025, Mr. Vaughn reimbursed Local 391 for the cost of food and beverages for the event, and the Teamsters United 2026 slate has forfeited all of the signatures collected at the event. Local 391 has been ordered to post this notice days to advise members that such conduct is a violation of the Rules and will not be tolerated.
The Election Supervisor issued this decision in Vargas, 2025, ESD 3. You may read this decision at https://www.ibtvote.org/Protest-Decisions/esd2025/2025esd003 .
Any protest you have regarding your rights under the Election Rules or any conduct by any person or entity that violates the Election Rules should be filed with the Hon. Timothy S. Hillman (Ret.), 1750 K Street, N.W., Suite 200, Washington, D.C. 20006, telephone: 844-428-8683, fax: 202-807-1074, email: electionsupervisor@ibtvote.org .
OFFICE OF THE ELECTION SUPERVISOR
for the INTERNATIONAL BROTHERHOOD OF TEAMSTERS
1750 K STREET, N.W., SUITE 200
WASHINGTON, D.C. 20006
844-428-8683 TOLL FREE
FAX: 202-807-1074
electionsupervisor@ibtvote.org
Hon. Timothy S. Hillman
Election Supervisor
NOTICE TO MEMBERS OF THE FACEBOOK GROUP TEAMSTERS OF THE CAROLINAS (UNOFFICIALLY)
Article VII, Section 12(a) of the Rules for the 2025-2026 IBT International Union Delegate and Officer Election (“Rules”) prohibits any candidate or member from campaigning during his or her work hours. Article VII, Sections 12(b) also prohibits union officers and employees from participating in campaign activities involving the expenditure of union funds including, but not limited to, campaigning on time paid for by the union. Officers and employers are permitted to endorse a candidate but solely in his or her individual capacity. Id. A local union is prohibited from endorsing or otherwise advancing a candidacy. Id. Article VII, Section 12(c) prohibits the use of union funds, equipment and other resources to assist with campaigning unless the union is reimbursed at fair market value, and all candidates are provided equal access and notified in writing in advance. Union officers and employees provided with a union vehicle who have the right to use the vehicle for personal activities, may use the vehicle for campaign activities provided no costs or expenses incurred as a consequence of such use are paid out of union funds or other prohibited sources. Article XI, Section 12(g) prohibits retaliation against any member for exercising any of their rights under the Rules.
The Election Supervisor found that Michael Bentley and Chris Vaughn violated Article VII, Sections 12(a)-(c) of the Rules in connection with an event on April 4, 2025 at the UPS Greensboro facility involving a petition drive by a member of the Teamsters United 2026 slate to collect signatures from members in connection with the IBT International Union Delegate and Officer Election and a membership drive to collect applications for membership in Local 391. Specifically, Mr. Bentley’s use of Local 391’s resources and equipment including, a truck, canopy, and tables to further the campaign of the Teamsters United 2026 slate and Mr. Vaughn’s use of Local 391’s funds to purchase the food and beverages for the event violated the Rules. Additionally, Mr. Bentley and Mr. Vaughn participation in campaign activities during work time violated the Rules.
Mr. Bentley and Mr. Vaughn have each taken a vacation day for August 4, 2025, Mr. Vaughn reimbursed Local 391 for the cost of food and beverages for the event, and the Teamsters United 2026 slate has forfeited all of the signatures collected at the event. Information about this event was posted to this Facebook group, therefore, Mr. Bentley has been ordered to post this notice days to advise members of this Facebook group that such conduct is a violation of the Rules and will not be tolerated.
The Election Supervisor issued this decision in Vargas, 2025, ESD 3. You may read this decision at https://www.ibtvote.org/Protest-Decisions/esd2025/2025esd003.
Any protest you have regarding your rights under the Election Rules or any conduct by any person or entity that violates the Election Rules should be filed with the Hon. Timothy S. Hillman (Ret.), 1750 K Street, N.W., Suite 200, Washington, D.C. 20006, telephone: 844-428-8683, fax: 202-807-1074, email: electionsupervisor@ibtvote.org.
**This is an official notice of the Office of the Election Supervisor. It must remain posted on the page for the Facebook group Teamsters of the Carolinas (Unofficially) for thirty (30) days and must not be defaced or covered up.
[1] Mr. Bentley stated that Rick Armstrong, Vice President of Local 391 and the UPS representative for IBT on the Eastern Seaboard, had previously been contacted about having a membership drive, which Mr. Armstrong delegated to Mr. Bentley.
[2] There is no evidence that these photographs have been distributed or posted elsewhere.
[3] As of the investigation, there were 564 members.
[4] Mr. Bentley stated that on July 8, 2025, the name of the Group was changed from “Teamsters of NC (unofficial)” to “Teamsters of the Carolinas (unofficially)” because Local 509 in Greenville, South Carolina, joined the group. Now, Teamsters of the Carolinas (unofficially) is available to members of Local 391, 61, 71 and 509.
[5] The member was on honorable withdrawal from Teamsters Local 538 and not a member of the MBWE Division.
[6] Article VIII, Section 11(a) of the 1996 Rules is identical in relevant respects to Article VII, Section 12 (a) of the current Rules.
[7] The exact cost of the beverages is unclear as the water and Gatorade was taken from the stock Local 391 keeps on hand for distribution to members for membership drives. However, Mr. Vaughn calculated the cost if the beverages distributed that day and based on the information gathered during the investigation, there is sufficient evidence to establish that the cost of the food and drinks in total did not exceed $300—the amount Mr. Vaughn reimbursed Local 391.
[8] As set forth above, this Facebook group is private and hidden, therefore, only members are able to access it, and the content posted therein.