Richardson, 2026 ESD 106
OFFICE OF THE ELECTION SUPERVISOR
for the
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
)
IN RE: PAMELA ) Protest Decision 2026 ESD 106
RICHARDSON, )
) Issued: June 3, 2026
Protester. )
) OES Case No. P-127-032726
)
)
INTRODUCTION
Pamela Richardson filed this protest against Dave Reeves, alleging that the Teamsters United 767 – The Dave Reeves Slate purchased pins that are being worn by all of the Local 767 stewards, as well as the Executive Board and Officers of Local 767. Richardson alleges that the pin was paid for by the union, and was modified to say “Teamsters United Slate” by members of the union who were paid by the union, in violation of the Rules. Richardson further alleges that the symbol being used on the pin is the established symbol of the current stewards, officers and Executive Board, also in violation of the Rules.
Dolores C. Hall of the Office of the Election Supervisor (“OES”) investigated these protests.
BACKGROUND & INVESTIGATION
Local 767 is entitled to 14 delegates and 7 alternate delegates at the Convention. Local 767’s nomination meeting was held on January 24, 2026, and the count occurred April 4, 2026.
The OES interviewed Pamela Richardson and Dave Reeves regarding this protest, and reviewed photographs provided by both Richardson and Reeves. Based on the evidence gathered, it is undisputed that in 2019, a previous officer of Local 767 ordered a pin (described as a “sheriff’s star”), paid for with union funds, that said “Teamsters” at the top and “Steward” at the bottom. In 2023, the officers then in office (including Dave Reeves) had the pin modified to remove the word “Steward” and replace it with “Local 767.” They also placed an image of a red, white and blue longhorn steer in the center of the pin. These new pins were also paid for with union funds.
Although Richardson alleges in her protest that the Teamsters United 767 – The Dave Reeves Slate has used union money to purchase pins that were further modified to say “Teamsters United Slate,” we have no evidence to support such claims. The evidence submitted by Richardson and Reeves shows, instead, that throughout the 2026 election period, the Teamsters United 767 – The Dave Reeves Slate produced and utilized campaign materials (including signs and shirts) that bore a modified image of the 2023 version of the pin. Specifically, images taken in early March, 2026 and provided to the OES by Richardson show supporters of the Teamsters United 767 – The Dave Reeves Slate wearing shirts and holding campaign signs depicting a version of the Sheriff’s star that replaces the word “Teamsters” with the phrase “Teamsters United 767,” and the phrase “Local 767” with the phrase “Dave Reeves Slate.” The red, white and blue longhorn steer remains in the center of the image. Above and below the modified star image on the campaign signs, the signs read “TEAMSTERS UNITED 767 FOR OZ.”
APPLICABLE LAW
Although the protester does not cite a particular rule that she believes was violated, we interpret her protest to allege a violation of Article VII, Section 12 and Article XI, Section 1(b) of the Rules. Article VII, Section 12 states, in pertinent part:
(b) All Union officers and employees, if members, retain the right to participate in campaign activities, including the right to run for office, openly to support or oppose any candidate, to aid or campaign for any candidate, and to make personal campaign contributions. However, such campaigning must not involve the expenditure of Union funds. . . .
(c) Union funds, facilities, equipment, stationery, personnel, etc., may not be used to assist in campaigning unless the Union is reimbursed at fair market value for such assistance, and unless all candidates are provided equal access to such assistance and are notified in advance, in writing, of the availability of such assistance. . . .
Article XI, Section 1(b) of the Rules states, in pertinent part:
(3) No labor organization, including but not limited to the International Union, Local Unions and all other subordinate Union bodies, whether or not an employer, may contribute, or shall be permitted to contribute, directly or indirectly, anything of value, where the purpose, object or foreseeable effect of the contribution is to influence, positively or negatively, the election of a candidate, except as permitted by subparagraphs (5) and (6) below. No candidate may accept or use any such contribution. These prohibitions extend beyond strictly monetary contributions made by a labor organization and include contributions and use of the organization’s stationery, equipment, facilities, and personnel.
. . .
(6) No Union funds or other things of value shall be used, directly or indirectly, to promote the candidacy of any individual. Union funds, facilities, equipment, stationery, personnel, etc., may not be used to assist in campaigns unless the Union is compensated at fair market value for such assistance, and unless all candidates are provided with equal access to such assistance and are advised in advance, in writing, of the availability of such assistance. The use of the Union’s official stationery with the Union’s name, insignia, or other mark identifying the Union is prohibited, irrespective of compensation or access. Other use of the Union’s name, insignia, or mark by Union members, in connection with the exercise of rights under these Rules, is permitted.
. . .
ANALYSIS AND FINDINGS
The Teamsters United 767 – The Dave Reeves Slate used, in its campaign materials, an image derived from a pin that was originally purchased and used by the union. The original pins, as well as the 2023 modified version, were paid for with union funds. However, there is no evidence that union funds were used to create or purchase the campaign materials bearing the modified pin image that were used by the Teamsters United 767 – The Dave Reeves Slate during the 2026 election cycle.. Although the pin was originally created for stewards, it was modified in 2023 to be more inclusive and available to all members of Local 767, not just stewards. Since then, the pin has been worn by rank‑and‑file members as well as by officers and stewards, and does not function as an indicia of incumbency.
Pursuant to Article XIII, Section 2(b) of the Rules, a pre‑election protest must be filed within two (2) working days of the date on which the complainant “became aware or reasonably should have become aware of the action protested,” or the protest is waived. “The requirement to promptly file protests is an important part of the election process. The short time limits are designed to quickly bring alleged violations of the Rules to the attention of the Election Officer. The Election Officer’s remedies are most effective when applied to a Rules violation filed in a timely manner.” PR-112-LU206-EOH (June 2, 1998) (emphasis in original).
“The Election Appeals Master has stated that ‘long public exposure’ of a fact justifies the inference of constructive knowledge.” PR-112-LU206-EOH (June 2, 1998) (quoting In re Heiman, 96 - Elec. App. - 172 (KC) (April 18, 1997)). Here, the meeting at which The Teamsters United 767 – The Dave Reeves Slate was nominated was held on January 24, 2026, and the protester provided photographs taken in early March, 2026 that depict The Teamsters United 767 – The Dave Reeves Slate supporters wearing or holding campaign materials bearing the modified Sheriff’s star. Because Richardson did not file her protest until March 27, 2026, more than two working days after she became aware or reasonably should have become aware of The Teamsters United 767 – The Dave Reeves Slate’s use of the modified star logo on its campaign materials (and only about a week before election day), this protest is untimely.
Accordingly, we DENY this protest.
Even if this protest had been timely filed, we would deny it on the merits. We have no evidence that union funds were used to create or purchase pins supporting The Teamsters United 767 – The Dave Reeves Slate during the 2026 election cycle, nor is there evidence that union funds were used to create or purchase the slate’s campaign materials depicting the modified star logo.
To the extent that the campaign materials bearing the modified star logo use an image that has become associated with Local 767, such use is permitted by the Rules. “While Article XI, Section 1(b)(6) prohibits use of union stationery, ‘[o]ther use of the Union’s name, insignia or mark by Union members, in connection with the exercise of rights under these Rules, is permitted.’ This language has been held to permit use of the IBT logo in campaign material.” Laszlo, 2011 ESD 87 (January 27, 2011). See also Lyons, 2006 ESD 101 (February 27, 2006) (use of modified IBT logo in campaign materials permissible); Saal, 2001 EAD 138 (February 6, 2001) (local union’s logo “may be used in campaign literature in the same fashion as the logo of the IBT.”). As discussed above, the image here was used solely in clearly identified campaign materials.
For these additional reasons, we would deny this protest on the merits.
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 106
DISTRIBUTION LIST (BY EMAIL UNLESS NOTED OTHERWISE):
Pamela Richardson
Dave Reeves
John Palmer
Richard Hooker
Edward M. Gleason, Jr.,
James L. Donovan Jr.
David Suetholz
Will Bloom
Ken Paff
Thomas Kokalas
Timothy S. Hillman
Paul Dever
Dolores Hall
Ellyn Lazar
Kelly Hogan