In re Eligibility of O’Neal, 2026 ESD 38
OFFICE OF THE ELECTION SUPERVISOR
for the
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
) Protest Decision: 2026 ESD 38
IN RE: ELIGIBILITY OF )
) Issued: February 5, 2026
LARRY O’NEAL )
) OES Case No. E-051-012026
)
)
INTRODUCTION
Patrick Gleason filed a pre-election protest pursuant to Article XIII, Section 2(b) of the Rules for the 2025-2026 IBT International Union Delegate and Officer Election (“Rules”) challenging the eligibility of Larry O’Neal to run for delegate in Local 26’s delegate election alleging that he has not met the requirement of being in good standing for 24 consecutive months pursuant to the Rules.
Ron Webne, a representative of the Office of the Election Supervisor (“OES”), investigated this protest.
BACKGROUND & ANALYSIS
The nomination meeting for Local 26 took place on Saturday, January 17, 2026, at 12:00 p.m. Gleason appears to have filed his protest on January 20, 2026, at 10:16 a.m. via e-mail. Pursuant to Article XIII, Section 2 (b) of the Rules, protests concerning the eligibility of candidates “must be filed within two (2) working days of the day when the protestor becomes aware or reasonably should have become aware of the action protested or such protests shall be waived.” If the time period began on January 18, 2026, and assuming that day and the following day (Martin Luther King, Jr. Day) were not working days, it would appear the protest was timely filed.
Pursuant to Article VI, Section 1(a) of the Rules, to be eligible to run for any Convention delegate, alternate delegate, or International Officer position, one must:
(1) Be a member in continuous good standing of the Local Union, with one’s dues paid to the Local Union for a period of twenty-four (24) consecutive months prior to the month of nomination for said position with no interruptions in active membership due to suspensions, expulsions, withdrawals, transfers or failure to pay fines or assessments;
(2) Be employed at the craft within the jurisdiction of the Local Union for a period of twenty-four (24) consecutive months prior to the month of nomination; and
(3) Be eligible to hold office if elected.
Pursuant to Article X, Section 5(c) of the IBT Constitution, dues must be paid on or before the last business day of the current month. Any member failing to pay dues at such time “shall not be in good standing status for such month.” Article X, Section 5(c) of the IBT Constitution provides an exception for members on dues checkoff whose employer fails to make a proper deduction during a month, but the exception does not apply here, because O’Neal confirmed that he pays his dues by check and that he was not on dues checkoff.
To be eligible (in addition to other requirements), O’Neal must have been “in continuous good standing, with his dues paid timely to the local union for the 24 consecutive months prior to the month of nomination…” Kelly, 2023 ESD 13 (Aug. 25, 2020) (emphasis added). TITAN records show that O’Neal’s dues for July 2024 were not paid until August 22, 2024, his dues for January 2025 were not paid until February 28, 2025, and his dues for July 2025 were not paid until August 21, 2025—which O’Neal does not dispute. Rather, O’Neal states that in 2024 he was working out of town six days a week and working 10-hour days on two different jobs causing him to pay his dues late.[1] Late payment of such dues “shall not restore good standing status for such month or months in computing the continuous good standing status required by Article II, Section 4 of this Constitution as a condition of eligibility for office.” IBT Constitution, Article X, Section 5(c). O’Neal’s failure to timely remit his full dues for the months of July 2024, January 2025, and July 2025 represent an interruption in his continuous good standing and render him ineligible.
Accordingly, we find that O’Neal is ineligible and GRANT this protest.
APPELLATE RIGHTS
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:
Election Appeals Master
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. 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. A copy of the protest must accompany the request for hearing.
Timothy S. Hillman
Election Supervisor
cc: Barbara Jones, IBTappealsmaster@bracewell.com
2026 ESD 38
DISTRIBUTION LIST (BY EMAIL UNLESS NOTED OTHERWISE):
Larry O’Neal
Edward M. Gleason, Jr.,
Richard Hooker
David Suetholz
Will Bloom
Ken Paff
Thomas Kokalas
Timothy S. Hillman
Paul Dever
Ron Webne
Bill Broberg
Kelly Hogan
[1] We did not have an email address for O’Neal on January 20, 2026, when the letter acknowledging this protest and assigning an investigator was sent to the protestor and others on the distribution list. However, on January 25, 2026, the investigator spoke with O’Neal to notify him of the protest and obtain his email address. That same day, we emailed him a copy of the acknowledgement letter and protest.
