Eligibility of Schmaus and Tatro-Morgan, 2026 ESD 48
OFFICE OF THE ELECTION SUPERVISOR
for the
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
) Protest Decision: 2026 ESD 48
IN RE: ELIGIBILITY OF )
JORDAN SCHMAUS and ) Issued: February 23, 2026
HILLARY TATRO-MORGAN )
) OES Case No. E-059-012926 &
) E-060-012926
INTRODUCTION
Walter LaChapelle, III 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”) challenging the eligibility of Jordan Schmaus (Protest No. E-059-012926 or E-059) and Hillary Tatro-Morgan (E-060-012926 or E-060) to run for delegate in Local 58’s delegate election.
Ron Webne of the Office of the Election Supervisor investigated these protests.
FINDINGS OF FACT AND ANALYSIS
LaChapelle claims that Schmaus and Tatro-Morgan are not eligible to run for delegate because they failed to timely pay dues throughout the 24 consecutive months leading up to Local 58’s nomination meeting.[1] LaChappelle provided documents showing Schmaus’ and Tatro-Morgan’s dues’ payment records in a format similar to TITAN in support of his protests.
LaChapelle does not allege that Schmaus’ or Tatro-Morgan’s active membership was interrupted by suspensions, expulsions, withdrawals, transfers or failure to pay fines or assessments, and TITAN does not reflect such an interruption for either Schmaus or Tatro-Morgan.
Pursuant to Art. VI, Section 1 (a)(1)-(3) 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.
The nomination meeting for Local 58 was held on January 27, 2026. Thus, to be eligible to run for delegate, Schmaus and Tatro-Morgan must have timely paid their dues for each month from January 2024 through December 2025 (the “Eligibility Period”).
Pursuant to Article X, Section 5(c) of the IBT Constitution, all members paying dues must pay them on or before the last business day of the current month. Any member failing to pay dues by that deadline shall not be in good standing and payment of such dues after the due date does not restore good standing status for that month (or months) in computing the continuous good standing status required by Article II, Section 4 of the IBT Constitution (governing eligibility to office). Id. (emphasis added). However, there is an exception:
a member on dues checkoff whose employer fails to make a proper deduction during any month in which the member has earnings from work performed during the month from which his dues could have been deducted, or has earnings from which the employer normally makes a dues deduction pursuant to the contract or established practice, shall not lose good standing status for that month. In such an event, the Local Union shall notify the member of the employer’s failure and payment shall be made by the member within thirty (30) days of said notice in order to retain good standing.
IBT Constitution, Art. X, Section 5(c) (emphasis added).
Eligibility of Jordan Schmaus
TITAN records show that Schmaus timely paid his dues during the Eligibility Period except as follows:
- His dues for January and February 2025 were paid on March 14, 2025; and
- His dues for July 2025 were paid on August 5, 2025.
Schmaus was on authorized dues checkoff with his employer, UPS, requiring UPS to deduct dues from his compensation and remit those dues to Local 58. He provided paystubs showing his earnings for work performed in each of the above referenced months sufficient to pay his dues. Thus, under the Article X, Section 5(c) of the IBT Constitution, Schmaus is deemed to have timely paid his dues for January, February and July of 2025. Accordingly, he did not lose good standing during the Eligibility Period as alleged in Protest No. E-059-012926.
We therefore find that Schmaus is eligible to run for delegate in Local 58’s delegate election and DENY Protest No. E-059.
Eligibility of Hillary Tatro-Morgan
TITAN records show that Tatro-Morgan timely paid dues during the Eligibility Period except as follows:
- Her dues for June 2024 were paid on August 30, 2024;
- Her dues for July and August 2024 were paid on September 16, 2024; and
- Her dues for July 2025 were paid on August 5, 2025.
Tatro-Morgan stated that she did not work in June, July or August 2024. However, she provided a paystub showing that she received vacation pay during the pay period June 23, 2024, through July 20, 2024, sufficient to pay her dues for June and July. Because Tatro-Morgan was on dues checkoff with her employer, UPS, and showed that she had sufficient compensation from UPS to pay her dues those months, she did not lose good standing for June or July 2024. See IBT Constitution, Art. X, § 5(c).
Tatro-Morgan did not, however, have any paystubs from her employer for pay periods in August 2024. She acknowledged that she did not receive any payment from UPS for compensation for work performed, vacation or sick leave and cannot rely on the checkoff rule for August 2024. She was required to make direct payment of her dues to Local 58 for August 2024 no later than the last business day of that month to maintain good standing. See In re Eligibility of Calhoun, 2021 ESD 40 (Jan. 12, 2021) (finding member’s continuous good standing requirement was not met because he could not rely on the checkoff rule while on leave and he had to pay his dues by the last business day of the month he was on leave).[2] Tatro-Morgan acknowledges that she did not pay her dues for August 2024 until September 16, 2024. Her admission was corroborated by the record evidence.[3] Since her dues for at least August 2024 were not timely paid, she was not in good standing with regard to payment of dues to Local 58 for that month interrupting her continuous good standing throughout the Eligibility Period.
Accordingly, we find that Tatro-Morgan is ineligible to run for delegate and GRANT Protest No. E-060-012926.
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 48
DISTRIBUTION LIST (BY EMAIL UNLESS NOTED OTHERWISE):
Walter LaChapelle III
walter.lachapelle@teamsters58.com
Jordan Schmaus
Hillary Tatro-Morgan
Edward M. Gleason, Jr.,
Richard Hooker
David Suetholz
Will Bloom
Ken Paff
Thomas Kokalas
Timothy S. Hillman
Paul Dever
Ron Webne
Deborah Schaaf
Kelly Hogan
[1] As part of the investigation, the investigator asked protestor if he alleged Schmaus or Tatro-Morgan were ineligible on any basis other than failing to timely pay their dues during the eligibility period. The protestor responded by referring to his protest, documents filed with it, the Rules, and his “understanding of previous protest decisions that have been issued by OES appearing in several cases, as nearly identical similarly situated circumstances discovered in the following cases.” The protestor provided links to OES protest decisions from the 2020-21 and current election cycles. We reviewed the numerous decisions cited, which discuss a wide variety of topics, including various challenges to members’ eligibility based on different eligibility requirements. These decisions do not provide any specificity to either protest.
[2] She states that she did, however, receive money from the Teamsters Welfare Trust for several months as a result of her disability and state FMLA in August 2024. She also stated that she did not apply for, and Local 58 did not approve, a leave of absence. See Rules, Art. VI, § 2(d).
[3] TITAN records show that Tatro-Morgan’s August 2024 dues were paid on September 16, 2024, as part of a $345.00 payment that brought Tatro-Morgan current on her dues through September 2024. She provided a receipt from Local 58, dated September 16, 2024, confirming this. As noted above, Tatro-Morgan also admitted that her dues for June, July, and August 2024 were not paid until September 2024. Specifically, she stated, “I was on injury-related leave during the relevant period and received no wages, I do not have paystubs to submit. * * * * * The months of June, July, and August 2024 were covered by the large direct payment I made on September 18, 2024.”