2026 EAM 18 (re: 2026 ESD 69)

ELECTION APPEALS MASTER
FOR THE INTERNATIONAL BROTHERHOOD OF TEAMSTERS

2026 EAM 18
ISSUED: June 11, 2026
APPEAL OF ELECTION SUPERVISOR PROTEST 2026 ESD 69
OES CASE No. P-111-030426

Protest Decision 2026 ESD 69 ("ESD 69") was issued on April 27, 2026 (OES Case No. P-111-030426) by the Office of the Election Supervisor (“Election Supervisor” or “OES”).  ESD 69 addresses a protest filed by Hillary Tatro-Morgan, a candidate in Local 58’s delegate election.  Ms. Tatro-Morgan alleged that the candidate listing on the printed ballots was confusing and the use of the “Teamsters United 58” slate name on the ballot was improper, both of which violated the Rules for the 2025-2026 IBT International Union Delegate and Officer Election (the “Rules”). The Election Supervisor denied the protest as untimely and determined, in the alternative, that the protest also failed on the merits.

On April 27, 2026, Ms. Tatro-Morgan appealed the decision, and submitted a supplemental written argument in support of her position.  On May 5, 2026, the OES submitted a supplemental written argument in support of its position.

A hearing by video conference was held on May 6, 2026.  The following individuals attended the hearing:  Kelly Hogan and Debra Schaaf on behalf of the OES; Hillary Tatro-Morgan; and Walter LaChappelle, Thomas Alcomendas and Justin Baptista on behalf of Local 58.  

For the reasons set forth below, the appeal is DENIED.

Background

Local 58 is entitled to elect two delegates and one alternate delegate to the June 2026 IBT International Convention. At the nomination meeting on January 27, 2026, four candidates for delegate and two candidates for alternate delegate were nominated.  Three of those candidates – two delegate candidates and one alternate delegate candidate – chose to run together as the “Teamsters United 58” slate.  The remaining three candidates, including Ms. Tatro-Morgan, chose to run as individual candidates unaffiliated with any slate.

On February 25, 2026, Merriman River Group, the third party responsible for administering Local 58’s delegate election, circulated to all candidates two proposed ballot designs for review and approval prior to printing:  (1) a “top-bottom” design, which listed the slate and candidates from top to bottom, and (2) a “left-right” design, which listed the slate and candidates from left to right.  Ms. Tatro-Morgan reviewed the proposed designs and, that same day, sent a text message selecting the top-bottom format, stating: “I prefer the strait [sic] ballot, not the side by side. Thank you for reaching out. Name is correct also.”  The ballots were printed on February 26, 2026 and mailed to the members on February 27, 2026.

The front of the ballot clearly states:

OFFICIAL BALLOT
FOR THE ELECTION OF CONVENTION DELEGATES AND ALTERNATE DELEGATES
TEAMSTERS LOCAL UNION 58

The ballot is organized into three distinct sections, each clearly labeled in bold and separated by bold lines:  (1) a “Slate” section instructing voters to "Vote for no more than ONE," and listing the “Teamsters United 58” slate next to a voting bubble; (2) a “Delegate” section instructing voters to “Vote for no more than TWO,” and listing each of the four delegate candidates (with the two Teamsters United 58 slate candidates identified as such); and (3) an “Alternate Delegate” section instructing voters to “Vote for no more than ONE,” and listing both alternate delegate candidates (again with the Teamsters United 58 candidate identified).  The back of the ballot contains detailed voting instructions, explains the difference between voting for a slate and voting for individual candidates, and expressly informs voters that by “placing a mark in the slate box, you will have voted for all the individual candidates on that slate.”

On March 4, 2026, approximately four weeks after receiving the recording of the candidates meeting and seven days after personally reviewing and approving the ballot design, Ms. Tatro-Morgan filed a protest with the Election Supervisor.  She alleged that the Teamsters United 58 slate name was improper and the ballot design mislead voters.

On March 10, 2026, Ms. Tatro-Morgan filed a supplemental protest raising two additional allegations.  First, she challenged a campaign flyer distributed by the national Teamsters United OZ slate endorsing the Teamsters United 58 local slate.  The flyer featured the OZ 2026 logo and directed members to vote for the Teamsters United 58 slate without any disclaimer stating the slate was not officially endorsed by the Local or IBT.  Second, she claimed that the presence of three current Local 58 executive board members among the Teamsters United 58 slate candidates indicated potential improper involvement by the executive board in forming the slate.  On March 23, 2026, Ms. Tatro-Morgan filed a supplemental argument in support of her protest.

Determination

1. Timeliness

The Rules provide that a pre-election protest “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.” Article XIII, Section 2(b). 

It is clear from the record that Ms. Tatro-Morgan became aware of the actions that are the subject of her protest by no later than February 25, 2026.  On that date, Ms. Tatro-Morgan explicitly approved the ballot design and was aware of both the Teamsters United 58 slate name and slate candidates.  Accordingly, I find that the protest filed on March 4, 2026 and the supplemental protest filed on March 10, 2026 regarding those claims were not timely filed under Article XIII, Section 2(b) of the Rules. [1]

1. Substantive Grounds on Appeal

i.     Ballot Design

Having reviewed the ballot, I agree with the determination of the Election Supervisor that its design and instructions were clear.  Further, the Election Supervisor confirmed at the hearing that following its review of the ballots submitted in the election, there was no indication, such as inconsistent markings or corrections, that the voters were confused by the design or layout.

ii          Teamsters United 58 Slate Name

I find that that the use of the slate name “Teamsters United 58” does not violate the Rules nor does it fall within any of the narrow circumstances under which the Election Supervisor has authority to regulate slate names.  See Davis & Meyer, 2016 ESD 112 (Feb. 16, 2016) (“we have approved slate names that incorporate the name of a candidate for International office or the local union name and number), citing Dietrich, P350 (Feb. 5, 1996) and Harrington, P159 (Sept. 27, 1995).  

iii.   OZ 2026 Campaign Flyer

I agree with the Election Supervisor’s determination that the campaign flyer distributed by the national Teamsters United OZ slate did not cause voter confusion as to endorsement by the Local or by the IBT.  The flyer at issue is clearly campaign literature of the Teamsters United OZ national slate, and an endorsement by one slate of another is explicitly permitted under the Rules.  See Thompson, 2001 EAD 232 (March 12, 2001) (“A slate may support the candidate of its choice.”). 

iv.     Alleged Involvement of the Local 58 Executive Board

            The Election Supervisor also correctly denied Ms. Tatro-Morgan’s separate allegations that Local 58’s executive board improperly colluded in the formation of the Teamsters United 58 slate or that the local misused union funds or resources.

For the foregoing reasons, I find that each of the grounds raised on appeal lacks merit. The appeal is DENIED.

SO ORDERED

Hon. Barbara S. Jones (Ret.)

Election Appeals Master

DATED: June 11, 2026