2026 EAM 9

ELECTION APPEALS MASTER

FOR THE INTERNATIONAL BROTHERHOOD OF TEAMSTERS

            Protest Decision 2026 ESD 48 (“ESD 48”) was issued on February 23, 2026 (OES Case Nos. E-059-012926 and E-060-012926 by the Office of the Election Supervisor (“Election Supervisor” or “OES”).   ESD 48 addresses a protest filed by Walter LaChapelle, III, Principal Officer of Local 58, challenging the eligibility of Hillary Tatro-Morgan to run as a delegate candidate pursuant to Article VI of the Rules for the 2025-2026 IBT International Union Delegate and Officer Election (the “Rules”).    

             On February 23rd, the Election Supervisor granted Mr. LaChapelle’s protest and found that Ms. Tatro-Morgan was ineligible to run as a delegate.  Ms. Tatro-Morgan appealed the decision that same day.  On February 24, 2026, by Notice of Hearing, the Election Appeals Master scheduled a hearing for February 25, 2026.  Also on February 24, 2026, the Election Supervisor submitted a revised determination finding that, upon further review of the record, Ms. Tatro-Morgan was eligible to run as a delegate candidate.

A hearing by video conference was held on February 25, 2026.  The following individuals attended the hearing:  Kelly Hogan and Deborah Schaaf, on behalf of the OES; Mr. LaChapelle on behalf of Local 58; and Ms. Tatro-Morgan on behalf of herself.

At the time of the hearing on February 25th, Local 58’s delegate election was imminent.  Accordingly, I issued a decision at the hearing on February 25th, RESOLVING the appeal based on the Election Supervisor’s further review of the record.  This written decision supplements my ruling issued at the hearing.

Determination

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.

According to Mr. LaChapelle’s protest, Ms. Tatro-Morgan was ineligible to run as a delegate in Local 58’s election because she had failed to pay her dues for 24 consecutive months prior to her nomination.  The Election Supervisor reviewed Ms. Tatro-Morgan’s dues payment history and determined that Ms. Tatro-Morgan did not work in June, July, and August 2024.  She was on dues check-off during those months and provided paystubs to the Election Supervisor for June and July showing that she received vacation pay or other earnings sufficient to cover her dues for those two months.  Pursuant to Article X, Section 5(c) of the IBT Constitution, she was properly deemed to have timely paid her June and July dues. See Thiel, 2010 ESD 16 (August 4, 2010).  However, the Election Supervisor initially determined that Ms. Tatro-Morgan had failed to timely pay her dues in August 2024, causing a break in her continuous good standing and rendering her ineligible to run as a delegate.  See ESD 48.

In her appeal, Ms. Tatro-Morgan asserted that she had paid her August 2024 dues directly to Local 58’s office manager on August 30, 2024.  Upon re-review of Ms. Tatro-Morgan’s dues payment history, the Election Supervisor confirmed this payment and determined that there had been no interruption in Ms. Tatro-Morgan's continuous good standing.  See OES Submission dated February 24, 2026.

At the hearing, Mr. LaChapelle objected to the Election Supervisor’s revised determination, arguing that it should be disregarded because it was based on new information not previously presented during the protest.  See In Re: O’Brien-Zuckerman 2021, 2020 EAM 3 (September 4, 2020); In Re: Cody Johnson, 2021 EAM 15 (March 22, 2021); In Re: Mark Bethel, 2025 EAM 1 (May 22, 2025) (absent extraordinary circumstances, the Election Appeals Master will not consider new claims or evidence submitted on appeal).  Although it is well established that no party may rely on new evidence during the appeal process, that principle is inapplicable here.

During the hearing, the Election Supervisor confirmed that Ms. Tatro-Morgan’s August 2024 payment was part of the original record but had been mistakenly credited to her September 2024 dues.  This error was identified and rectified upon re-review of her dues payment history.  Accordingly, the Election Supervisor properly determined that there was no interruption in Ms. Tatro-Morgan's continuous good standing and that she was eligible to run as a delegate.

Based on the foregoing, the appeal is RESOLVED.

SO ORDERED

Hon. Barbara S. Jones (Ret.)

Election Appeals Master

DATED:         March 24, 2026
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