Reynoso,2025 ESD 17
OFFICE OF THE ELECTION SUPERVISOR
for the
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
IN RE: REYNOSO, EDWARD ) Protest Decision 2025 ESD 17
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) Issued: November 24, 2025
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Protestor. ) OES Case No. P-024-110325-GP
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INTRODUCTION
Edward Reynoso, employee and member of Teamster Local 320, filed a protest against Jackson Kerr, Christy O’Connor, and Curtis Marquart, candidates on the 320 Teamster Action slate (“320 Teamster Action Slate”) in Local 320’s officer election (“Local Officer Election”) and the International Brotherhood of Teamsters 2026 International Union Delegate and Officer Election (“IBT Delegate Election”), pursuant to Article XIII, Section 2(b) of the of the Rules for the International Brotherhood of Teamsters 2026 International Union Delegate and Officer Election (“Rules”). Reynoso alleges that the 320 Teamster Action Slate improperly solicited and accepted campaign contributions from nonmembers in violation of Article XI, Section 1(b)(4) of the Rules.
The Office of Election Supervisor’s Jim Devine investigated this protest. The investigation included interviews of Brian Aldes, Secretary-Treasurer of Local 320, Christy O’Connor, Curtis Marquardt, and Marissa Bremer-Roark, supporter of the 320 Teamsters Action Slate. Additionally, the investigation included review and analysis of all materials submitted by the interested parties and witnesses in connection to these protests and independent investigation.
BACKGROUND
Local 320 is running its Local Officer Election and IBT Delegate Election concurrently. The nomination meeting for both elections was on November 1, 2025. Kerr, O’Connor and Marquiardt are running on the 320 Teamster Action Slate for both the Local Officer Election and IBT Delegate Election. The ballots for the Local Officer Election were mailed on November 7, 2025, and the ballot count is December 5, 2025. The ballots for the IBT Delegate Election have not yet been mailed. They are scheduled to be mailed on December 1, 2025, and the ballot count is December 29, 2025. It is clear that the 320 Teamsters Action Slate is currently campaigning only for its Local Officer Election. For example, Kerr, as head of the 320 Teamster Action Slate, has repeatedly acknowledged that he is actively campaigning for the Local Officer Election only.[1]
On November 3, 2025, Reynoso, a supporter of the 320 Teamsters United Slate running against the 320 Teamster Action Slate, saw a repost by O’Connor on his Facebook feed for a raffle conducted by the 320 Teamster Action Slate that was originally posted by Marissa Bremer-Roark. He provided a copy of the post which shows that the original post was published on October 13, 2025. Reynoso filed the subject protest with the Office of the Election Supervisor because soliciting funds through a public raffle for the IBT Delegate Election is a violation of Article XI, Section b94) of the Rules. Reynoso also stated that he filed a pre-election protest with Local 320 for the same conduct.
Bremer-Roark, who has been involved in other (non-union) campaigns came up with the idea of conducting a raffle with prizes to solicit more funds to support the 320 Teamster Action Slate in connection with the Local Officer Election rather than simply asking for donations. They advertised this raffle on Facebook[2] and by word of mouth. Bremer-Roark posted the original Facebook post advertising the raffle on October 13, 2025.[3] O’Connor then reposted Bremer-Roark’s post on October 18, 2025. A copy of the re-post is below:
Notably, the post states, “running a campaign is expensive as all get out” and that the slate is “putting it all on the line here to get us across the finish line.”
Reynoso stated that he first saw the post about the raffle on November 2, 2025, and he filed the protest on November 3, 2025. The raffle is open to the public—which Kerr and the 320 Teamster Action Slate do not dispute. There is a disclaimer on each raffle ticket that “320 Teamster Action does not accept donations from employers. Ticket must be filled out completely to be eligible to win.” To purchase a ticket, the buyer fills in the ticket with his or her name, telephone number, e-mail address, and employer. There is no space available for, or a requirement that, purchasers identify whether or not they are IBT members before purchasing the tickets. In other words, while the 320 Teamster Action Slate is monitoring that no employer’s purchase a raffle tickets, they are allowing non-Teamster members to purchase tickets. Tickets can be purchased in a number of ways including cash, PayPal, Venmo or Zelle. The PayPal, Venmo and Zelle accounts connected to the raffle proceeds are registered to Marquardt. Purchasers can purchase one ticket for $10, five for $20 or 15 for $50. The prizes include a flat screen tv, a $100 grocery card, and a personalized slate sweatshirt. Kerr was responsible for collecting tickets sold and the drawing. The raffle began mid-October. The raffle drawing was scheduled for November 15, 2025, but it did not occur at that time because 320 Teamster Action wanted to continue it for a longer period of time.
The raffle drawing will no longer occur. On November 17, 2025, a representative of the Minnesota Gambling Control Board contacted Kerr about the raffle and told him to cancel it. According to Kerr, based on an agreement with the Minnesota Gambling Control Board, Kerr will contact all the participants in the raffle to provide them with the options of donating their money or taking a refund.
Kerr, Bremer-Roark, O’Connor, and Marquardt all stated that the raffle was set up specifically to solicit funds to support the 320 Teamster Action Slate in connection with Local 320’s Local Officer Election only and that no funds were solicited in connection with the IBT Delegate Election. They further stated that none of the funds received from the raffle will be used in connection with the IBT Delegate Election. Curtis Marquardt, the Treasurer for the 320 Teamster Action Slate, confirmed that all of the funds solicited by the raffle are being depositing into a bank account for the 320 Teamster Action Slate that he controls. He stated that 320 Teamster Action has only one financial account set up and that all funds are being directed to their campaign for the Local Officer Election.
Kerr stated that all funds received by the 320 Teamster Action Slate have been used only to campaign for the Local Officer Election. Curtis Marquardt, treasurer for the 320 Teamster Action Slate, confirmed that all funds received or collected by the 320 Teamster Action Slate have been raised or spent in connection with the Local Officer Election and that no funds have been raised or spent on campaigning for the IBT Delegate Election. He went on to explain that the 320 Teamster Action Slate will open a separate account after the Local Officer Election if they decide to campaign for the IBT Delegate Election, which will depend on the outcome of the Local Officer Election.
ANALYSIS
Jurisdiction
“Pursuant to Article III, Section 5(a)(2) of the IBT Constitution and the 2026 Election Agreement, the Election Supervisor has the authority to conduct and supervise the election of delegates to the International Convention, the nomination of candidates for International office at the Convention and the election of International officers.” Rules, Art. I (emphasis added). This authority includes supervising “all phases of the International Union delegate and officer elections” including determining protests “concerning the elections[.]” Id. (emphasis added); see also Rules, Art. II, Section 1. The Election Supervisor has no jurisdiction over matters not related to the IBT International Union delegate and officer elections. See e.g., Darsey, P-276-LU528-SEC (Jan. 24, 1991); Meyers, P-493-LU999-PNJ (April 4, 1996); see also Webb & Thomas, 2010 ESD 56 (Dec. 13, 2010).
The Rules expressly permit local unions to run local officer elections concurrently with their delegate elections. See Rules, Art. II, Section 3(a)(1) (permitting local unions with a regularly scheduled local union officer election in the Fall of 2025 to also conduct its delegate nomination and election in the fall of 2025); see also Rules, Art. II, Section 7. However, the two elections are to be conducted separately, and the Election Supervisor’s authority is still limited to conduct related to the International Brotherhood of Teamsters International Union Delegate and Officer Election. See Rules, Art. II, Section 7(b) (“For those Local Unions electing delegates and alternate delegates at the same time as Local Union officer elections, the delegates and alternate delegates shall be elected in an election separate from the election of Local Union officers.”).
Campaign Contributions under the Rules
Article XI, Section 1(b) sets forth the rules applicable to “all campaigns for nomination or election in the positions of Convention delegate or alternate delegate and of International Officer positions[.]” Article XI, Section 1(b)(4) states:
No candidate, slate or independent committee, nor anyone acting on their behalf, may solicit or accept financial support, or any other direct or indirect support of any kind, from any nonmember, except as permitted in subparagraphs (5) and (9) below. Nonmember includes any former member of the IBT (including a retiree). Nonmember does, not include a member's immediate family, which is defined as a member's spouse, parents, children, or siblings, unless such family member is otherwise ineligible to contribute under these Rules.
Pursuant to Article XI, Section 1(b)(5), financial support or services from nonmembers “to pay fees for legal or accounting services” not to exceed $10,000 in certain circumstances is permitted.
As set forth in the July 17, 2025, Advisory on Campaign Contributions, Expenditures and Disclosure posted on the ibtvote.org website, candidates and slates participating in the International Union delegate and alternate delegate elections are required to keep and maintain sufficient records to demonstrate compliance with the Rules. See Advisory on Campaign Contributions, Expenditures and Disclosures, p. 1 (citing Rules, Article XI, § 2(b)(1)). Additionally, only contributions “properly solicited, made, accepted and reported” for the 2025-2026 IBT International Union Delegate and Officer Election may be used to support or oppose candidates in this election. Id. (citing Rules, Article XI, § 1(b)(1)). Funds originally solicited for other elections, whether at the International or local level, or solicited and pooled for another purpose, cannot be re-directed to support or oppose candidates in the 2025-2026 IBT International Union Delegate and Officer Election. Id. (citing Certain Campaign Contributions by Officers and Employees of Local Union 78, 2006 ESD 363 (October 4, 2006). Each candidate, slate and independent committee is subject to audit by the Election Supervisor upon notice. Id. at p. 26 (citing Rules, Article XI Section 2(b)(1)).
As we have found in prior protest decisions, absent evidence of conduct directly related to the International Brotherhood of Teamsters 2026 International Union Delegate and Officer Election, the mere fact that a candidate or slate has the status of being a candidate in the delegate election running concurrently with a local officer election is insufficient to establish that the Election Supervisor has jurisdiction. See Skoog, 2025 ESD 15 (Nov. 24, 2025); Reynoso, ESD 16 (Nov. 24, 2025). Compare Webb & Thomas, 2010 ESD 56 (despite touching on the delegate election, the evidence showed a direct link to the local officer election and was not sufficient to establish jurisdiction), Kantrowitz PR-033-LU705-NCE, (Dec. 16, 1997) (“The evidence presented is insufficient to show that any of Mr. Kantrowitz’s campaign efforts were made on behalf of International candidates. Therefore, the Rules are not applicable to the allegations made in this protest”), and Darsey, P-276-LU528-SEC (Jan. 24, 1991) (denying the protest because the Election Officer had no jurisdiction over matters unrelated to the IBT International Union delegate and officer election and any “turmoil” at the meeting “was related to intra-Union issues other than issues regarding or concerning the 1991 IBT International Union delegate or officer election” and there was no evidence that the remarks were based on the candidacy for alternate delegate or any other campaign activity) with Scherer, 2011 EAD 82 (Jan. 19, 2001) (the Election Supervisor had authority over conduct that clearly related to the delegate election); and Bethel, 2025 EAM 1 (May 22, 2025) (holding that the protestor was “clearly campaigning” for both the local officer election and the delegate election where, the facts showed that in addition to being a candidate in both elections, the slate’s campaign literature referenced elections in 2026 and 2027 (aka the delegate election and local union officer election) and the petitions circulated during the campaign activity that was the subject of the protest specifically stated, “By signing this document, I support the Bethel Unity Slate for the 2026 IBT Local Delegates and the 2027 Teamsters Local 31 elections”) (emphasis added).
Examining the totality of the circumstances surrounding the campaign activity at issue here, as we must, we find that the evidence shows that it relates to the Local Officer Election only. It is undisputed that the raffle was open to the public and not limited to Teamsters members. However, the 320 Teamster Action Slate stated that all of the funds collected pursuant to the raffle has been or will be used for the Local Officer Election only and none will be used in connection with the IBT Delegate Election. In fact, there is no evidence that the 320 Teamster Action Slate is actively campaigning for the IBT Delegate Election let alone using the contributions from the raffle to do so.
In addition to the witness statements that all funds are to be used only in connection with the Local Officer Election, the Facebook post itself suggests this is true. For example, it references “putting it all on the line here to get us across the finish line.” As discussed above, the ballots for the Local Officer Election were mailed in early November and the ballot count occurs on December 1, 2025. The ballots for the IBT Delegate Election have not even been mailed yet. It is clear that the Local Officer Election is the election the 320 Teamster Action Slate is trying to get “across the finish line.” Additionally, this is consistent with review of all campaign materials posted on the 320 Teamster Action Facebook page and website and other campaign activities. See Skoog, 2025 ESD 15 (Nov. 24, 2025) (discussing how all campaign materials and activities directly relate to the Local Officer Election, not the IBT Delegate Election); see also Reynoso, ESD 16 (Nov. 24, 2025) (discussing Kerr’s campaign activities in connection with the Local Officer Election). Accordingly, we DENY the protest.
We note, however, that the 320 Teamster Action Slate acknowledged that it currently has one account which is used for the Local Officer Election, and we remind them, as discussed above, that any contributions from the raffle or otherwise solicited for another purpose including the Local Officer Election are strictly prohibited from being re-directed to support or oppose candidates in the 2025-2026 IBT International Union Delegate and Officer Election. Each candidate and slate participating in the International Union delegate and alternate delegate elections is required to keep and maintain sufficient records to demonstrate compliance with the Rules and are subject to audit by the Election Supervisor upon notice. Rules, Article XI Section 2(b)(1).
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
2025 ESD 17
DISTRIBUTION LIST (BY EMAIL UNLESS NOTED OTHERWISE):
320 Teamster Action Slate
Jackson Kerr
Brian Aldes
Edward M. Gleason, Jr.,
David Suetholz
Will Bloom
Ken Paff
Thomas Kokalas
Timothy S. Hillman
Paul Dever
Jim Devine
Dolores Hall
Kelly Hogan
[1] Kerr has not only stated that his focus on the Local Officer Election at this time during the investigation of this protest but also during the investigation of various other protests filed by and against him.
[2] The raffle was not conducted on Facebook but Facebook was used to advertise the raffle.
[3] Others may have also posted a Facebook post about the raffle on or about October 13, 2025.