Eligibility of Duppman, Meza et al., 2026 ESD 34
OFFICE OF THE ELECTION SUPERVISOR
for the
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
) Protest Decision: 2026 ESD 34
IN RE: ELIGIBILITY OF )
STEVE DUPPMAN, ) Issued: January 30, 2026
CHRISTOPHER MEZA, )
JILL MARIE SMITH, and ) OES Case No. E-043-010826;
FRANCISCO VARGAS ) E-044-010826
)
)
INTRODUCTION
Dale Wentz 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 Steve Duppman, Christopher Meza, Jill Marie Smith, and Francisco Vargas, all candidates for delegate or alternate delegate in Local 150’s delegate election. Specifically, protestor alleges that the above referenced members are not eligible because:
- Duppman does not have 24 consecutive months of continuous good standing because he was on withdrawal status from June 2024 until January 2025, and returned to withdrawal status in May 2025 through December 2025;
- Meza does not have 24 consecutive months of continuous good standing because he was on withdrawal status in March of 2025 through July 2025;
- Smith does not have 24 consecutive months of continuous good standing because she was on withdrawal status from August 2024 to October 2024 and returned to withdrawal status in August 2025 to October 2025;
- Vargas does not have 24 consecutive months of continuous good standing because he was on withdrawal status from November 2024 to January 2025.
We consolidated these protests, as they all arise out of the challenged eligibility of candidates out of Local 150. Ron Webne, a representative of the Office of the Election Supervisor (“OES”), investigated these protests.
FINDINGS OF FACT AND ANALYSIS
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.
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).
“Continuous good standing” means compliance with the provisions of Article X, Section 5, concerning the payment of dues for a period of twenty-four (24) consecutive months, together with no interruptions in active membership in the Local Union for which office is sought because of suspensions, expulsions, withdrawals, transfers, or failure to pay finds or assessments. Provided, however, that if a member on withdrawal deposits the card in the month immediately following the month for which it was effective and pays dues for both months in a timely manner as provided in Article X, Section 5(c), such period of withdrawal shall not be considered a break in continuous good standing in the Local Union.
IBT Constitution, Art. II, Section 4(a)(1) (emphasis added).
After speaking with “Tammy” and Kim Chang, who are both TITAN operators for Local 150, about these protests, we determined that it is Local 150’s policy to summarily place a member on withdrawal status when the member’s employer does not remit a dues payment for a month whether or not the member requests it or notifies the local that they are not working. Local 150 will also summarily place a member on withdrawal when the member’s employer informs the local that the member is not working. This is sometimes prompted when the local does not receive dues for a month, and the TITAN operator either calls the employer to find out why, or the employer otherwise contacts the local to inform them. Thus, Local 150 has placed members on withdrawal status without a request by, notice to, or consultation with the member and waived dues for the month in which it did not receive a checkoff payment without notice to the member. Said differently, when the local does not receive a dues payment, it assumes the member is not working and automatically places him or her on withdrawal.
Withdrawal cards not issued at the request of a member but as a result of a local union policy do not affect a candidate’s eligibility so long as he or she had earnings from which dues could be deducted during the period in which they were put on automatic, unrequested withdrawal. See Gergely, E-029-LU395-EOH (January 17, 1996) (withdrawal issued not at the request of a member but as a result of a local union policy does not affect a candidate’s eligibility so long as he or she had earnings from which dues could be deducted during the period in which they were put on automatic, unrequested withdrawal); E.g., Rabine, E-019-LU763-EOH (Jan. 29, 1996) (finding the member, who did not request withdrawal but was placed on withdrawal status by the local automatically, was eligible because he had earnings from which dies could be deducted during the period in which he was put on automatic, unrequested withdrawal); Meadows, E-040-LU916-EOH (Jan. 30, 1996); Schock, 2000 EAD 13, (Aug, 14, 2000) (“where a local union issues a withdrawal card not at the member’s request but because of local union policy, the withdrawal is not to be considered an interruption in the member’s continuous good standing status so long as a member on check-off had sufficient earnings from which dues could have been deducted during the months in question.”) (cases collected).
The nomination meeting for Local 150 took place on January 7, 2026. Thus, to be eligible, among other requirements, each of the candidates discussed below must have been a member in good standing of Local 150 continuously from January 1, 2024, through December 31, 2025, without interruptions in active membership due to, among other things, withdrawals.
Steve Duppman
Wentz claims that Duppman has not been a member in good standing in Local 150 for the entire 24-month period ending in the month prior to the month in which the Local 150 nomination meeting took place because Duppman was on withdrawal beginning June 2024 to January 2025, and again in May 2025 returning December 2025.
TITAN records show that Duppman was on withdrawal three times during the relevant 24-month period (January 1, 2024 through December 31, 2025):
· September 5, 2024, returning November 1, 2024;
- February 25, 2025, returning the same day; and
- August 6, 2025, returning December 29, 2025.
The records also show that Duppman, who was on dues checkoff, made a payment of dues on June 18, 2024, which brought him current through June 2024. His next payments were made on February 26, 2025, when he paid two month’s dues, bringing him current through February 2025. Thus, he did not pay dues for the months of July 2024 through December 2024.
Duppman then made a payment of dues on May 15, 2025, making him current through May 2025. His next payment was a cash payment on December 29, 2025, consisting of eight months’ dues plus one dollar. This brought him current through January 2026 and ostensibly represented payment of his dues for the period June 2025 through January 2026. Dues for June through November 2025, however, were not timely paid (i.e., by the last business day of the month) and according to TITAN, dues for the period July 2024 through December 2024 remain unpaid.
Chang stated that Duppman’s employer notified the local that Duppman went on a leave of absence from work beginning June 24, 2024, so the local placed him on withdrawal effective September 5, 2024. Immediately before the entry of the withdrawal on September 5, 2024, the following note[1] appears on Local 150’s version of Duppman’s TITAN record: “PER COMPANY ON LOA[2] 6/24/2024.”
The next note states: “PER COMPANY 10/24/2024 RTW.”[3] According to Chang, Duppman was expected to return to work on November 1, 2024, thus TITAN reflects that he was returned to active status on that date. However, it does not appear that Duppman returned to work on that date. Rather per the notes in TITAN, Duppman was not able to return to work until January 4, 2025. The next note states: “LOA: 9/23/24 – 1/4/25 PER EMPLOYER.”
TITAN reflects that Duppman went on withdrawal on February 25, 2025, returning the same day. Chang explained that since Duppman was taken off withdrawal as of November 1, 2024, but actually did not return to work until January 4, 2025, the TITAN operator entered a withdrawal on February 25, 2025, the day before his dues’ payments on February 26, 2025, were made, so that he would not be charged dues for the months he actually did not work.
The next Local 150 note reads as follows: “PER COMPANY ON LOA 4/28/2025.” TITAN reflects that Duppman was then, again, placed on withdrawal August 6, 2025, and, as noted, returned to active status December 29, 2025. It is unclear whether he returned to work at that time.
There is no evidence that Duppman asked to go on any of the withdrawals that appear on TITAN. Rather, the TITAN operator notes indicate that Duppman’s employer informed the TITAN operator that Duppman was on a leave of absence at various times prompting the TITAN operator to put him on withdrawal. Nevertheless, it appears that according to the employer, Duppman was on a leave of absence from June 2024 through January 4, 2025. and again, beginning on April 28, 2025.
We have been unable to determine whether Duppman had earnings in the many months his dues were paid late or not paid at all between January 1, 2024 and December 31, 2025, because he has not responded to requests for information from the investigator. This protest was filed on January 8, 2026. That same day, we emailed Duppman an acknowledgement letter notifying him of the protest and assigned investigator, and asking in bold letters that all parties, which includes Duppman, “immediately provide our investigator with all information relevant to the allegation(s) contained in the protest…”[4] On January 13, 2026, the investigator e-mailed Duppman seeking additional information about the above issues, including whether the periods of withdrawal were voluntary. He did not respond. The investigator emailed him again on January 28, 2026, asking for the same information and paystubs showing his earnings for the months in which dues were not paid or paid late. Duppman did not respond to this email either. The investigator also called Duppman on January 26 and 28, 2026, and left messages asking him to call the investigator. He has not done so. Finally, Deborah Schaff, Regional Director in the Far West Region where Local 150 is located, called Duppman and left a message asking him to call her. He has not responded.[5]
Even if the withdrawals were not voluntary, Duppman would still have the problem of many payments that were either paid late or never paid. Duppman is a steward in Local 150, and given the responsibility this implies, one would expect him to respond to our efforts to obtain information that might be helpful to his candidacy, if, indeed, that information existed. Instead, he had declined to offer any information. Thus, the evidence we are left to with is the TITAN records and the unchallenged representations of the Local 150 TITAN operator that, according to Duppman’s employer, he was on a leave of absence from work during the months dues were not paid or paid late. Based on the information before us, including but not limited to, the reasonable inference that Duppman has not responded to the OES’s efforts to obtain information for weeks is because it would not show that Duppman had earnings from which his employer could have deducted dues, we find that Duppman was not a member in continuous good standing for the required 24-month period.
Accordingly, we find Duppman ineligible for delegate and GRANT the protest as to the allegations against him.
Christopher Meza
Wentz claims that Meza has not been a member in good standing in Local 150 for the entire 24-month period ending in the month prior to the month in which the Local 150 nomination meeting took place because Meza went on withdrawal in March 2025 returning July 7, 2025.
TITAN records show that Meza went on withdrawal on March 3, 2025 and returned to active membership July 7, 2025. These records are corroborated by one of the TITAN operators at Local 150, Kim Chang. Chang stated that on February 27, 2025, Meza informed a TITAN operator that he was taking a leave of absence from work and the TITAN operator put him on withdrawal as of March 3, 2025. Although Chang stated that Meza requested to go on withdrawal, it appears she assumed this was the case. Chang could not say if Meza used those exact words during his conversation with the other TITAN operator. Notwithstanding, Chang stated that the purpose of notifying the local that Meza (or any other member) was not working would be to notify the local that they were not working so that they did not have to pay dues during that period of unemployment. When Meza returned to work in July 2025, he notified a TITAN operator who restored his membership to active status.
TITAN records also show that Meza, who was on dues checkoff, made a payment of dues on February 2, 2025, which brought him current through that month. His next payment was a payment of one month’s dues on July 7, 2025, which brought him current through July 2025. Thus, he did not pay any dues for the months of March, April, May, or June 2025, which is consistent with Chang’s statements that we find credible.
This protest was filed January 8, 2026. That same day, the Election Supervisor sent an acknowledgement letter notifying interested parties of the protest and assigned an investigator, and asking in bold letters that all parties, which includes Meza, to “immediately provide our investigator with all information relevant to the allegation(s) contained in the protest…”[6] Our investigator emailed Meza on January 16, 2025, and January 26, 2026, asking for information concerning his withdrawal and the dues that were not paid. He has not responded to these emails. Our investigator also called Meza on January 26 and 28, 2025, at the phone number shown on the IBT vote Protest Form. He did not answer.[7] Again, we would expect Meza to respond to the investigator and provide the additional information requested, if, indeed, such information existed. Instead, Meza has declined to dispute these allegations.
Thus, the evidence we are left to with is the TITAN records and unchallenged representations of the Local 150 TITAN operator that Meza was on a leave of absence during the subject time period. Based on the information before us, we find that Meza was not a member in continuous good standing for the required 24-month period.
Accordingly, we find that the evidence shows Meza is ineligible for delegate and we GRANT the protest as to the allegations against him.
Jill Marie Smith
Wentz challenges the eligibility of Jill Marie Smith to run for delegate from Local 150. Wentz claims that Smith was not a member in good standing in Local 150 for the entire 24-month period ending in the month prior to the month in which the Local 150 nomination meeting took place. He claims that Smith was on withdrawal from August 2024 to October 2024, and again from August 2025 to October 2025.
TITAN records show that Smith went on withdrawal September 26, 2024, returning only one month later on October 25, 2024, and that her dues for September 2024 were not paid. TITAN records also show that Smith went on withdrawal on September 30, 2025, again, returning one month later on October 31, 2025, and that her dues for September 2025 were not paid.
Smith denies requesting, wanting, or playing any part in being placed on withdrawal. According to the TITAN operators at Local 150, Tammy and King, Smith was placed on withdrawal by the TITAN operator on both occasions because the local did not receive dues from Smith’s employer each month. Both TITAN operators stated that Smith did not request to go on withdrawal. Rather, both times they assumed Smith was not working because her dues payment was not made. Both operators said Smith’s withdrawal was subsequently lifted when they received the dues payment from the employer, just one month later (which was on October 25, 2024 and October 31, 2025, respectively).
Here, it is clear that the local placed Smith on withdrawal without her request or notifying her. Smith states that she was not informed that she had been placed on withdrawal or that dues for September 2024 and September 2025 had not been paid. Moreover, she provided paystubs showing earnings for work performed in September 2024 and September 2025, from which her dues could have been deducted. Since she was on dues checkoff, her employer should have deducted her dues but did not. Notwithstanding, she did not lose good standing for those two months because of the exception for late payments for members on checkoff contained in Article X, Section 5(c) of the IBT Constitution.
Finally, even if Smith had asked to be on withdrawal, the withdrawal card was deposited in both instances in the month following the month in which it was effective, and Smith either paid, or is deemed to have paid, her dues for both months. Thus Article II, Section 4(a)(1) of the IBT Constitution would apply, and the withdrawal would not affect her good standing.
Accordingly, we find that Smith is eligible and DENY the protest as to the allegations against her.
Francisco Vargas
Wentz challenges the eligibility of Franscisco Vargas to run for alternate delegate from Local 150. Wentz claims that Vargas has not been a member in good standing in Local 150 for the entire 24-month period ending in the month prior to the month in which the Local 150 nomination meeting took place. He claims that Vargas was on withdrawal from November 2024 to January 2025.
TITAN records show that Vargas went on withdrawal December 18, 2024, returning to active status on January 15, 2025, and that his dues for December 2024 were not paid. According to King, Vargas was placed on withdrawal because his employer reported that he was not working in December 2024. He was “brought back” when he made a dues payment on January 15, 2025.
Vargas denies requesting, wanting, or playing any part in being placed on withdrawal. Chang did not dispute this, and there is no evidence that Vargas requested being placed on withdrawal. Additionally, Vargas stated that he was not informed that he had been placed on withdrawal or that his dues for December 2024 had not been paid. He provided a paystub showing earnings for work performed in December 2024. Since he was on checkoff, his employer should have deducted his dues but did not. Notwithstanding, like Smith, Vargas did not lose good standing because of the exception for late payments for members on checkoff contained in Article X, Section 5(c) of the IBT Constitution.
Moreover, even if Vargas had asked to be placed on withdrawal, the withdrawal card was deposited in the month following the month in which it was effective, and Vargas either paid, or is deemed to have paid, his dues for both months. Thus Article II, Section 4(a)(1) of the IBT Constitution would apply, and the withdrawal would not affect his good standing.
Accordingly, we find that Vargas is eligible and DENY the protest as to the allegations against him.
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 34
DISTRIBUTION LIST (BY EMAIL UNLESS NOTED OTHERWISE):
Dale Wentz
Steve Duppman
Christopher Meza
Meza.A.christopher@outlook.com
Jill Marie Smith
Francisco Vargas
Edward M. Gleason, Jr.,
Richard Hooker
David Suetholz
Will Bloom
Ken Paff
Thomas Kokalas
Timothy S. Hillman
Paul Dever
Ron Webne
Kelly Hogan
[1] Chang provided us with Duppman’s TITAN record, which contains entries by Local 150 TITAN operators reflecting communications he or she had with Duppman’s employer.
[2] LOA means leave of absence.
[3] RTW means return to work.
[4] We note that we did not receive an automatic reply from mail delivery subsystem stating that the email this was sent to was undeliverable.
[5] We note that Duppman has not responded as of the date this decision was written.
[6] We note that we did not receive an automatic reply from mail delivery subsystem stating that the email this was sent to was undeliverable.
[7] Meza’s voicemailbox was full, and the investigator could not leave a message.