Blesedell v. Chillicothe Telephone Co.
811 F.3d 211
6th Cir.2016Background
- Jason Blesedell, a CTC plant facilities technician and union member, was fired for allegedly falsifying a timecard, modifying a trouble ticket, and impersonating a customer in recorded calls.
- Key evidence against Blesedell: GPS vehicle records, dispatcher call logs/recordings, a modified trouble ticket with inconsistent dates, and recorded anonymous calls on Dec. 16 that management and union officers believed sounded like Blesedell.
- The Union (IBEW Local 578) pursued Steps 1–3 of the CBA grievance process, reviewed CTC evidence, obtained Blesedell’s statement and affidavits, consulted international union representatives, and ultimately the grievance committee voted not to arbitrate.
- Blesedell sued CTC (breach of CBA) and the Union (breach of duty of fair representation) as a hybrid § 301 claim, and sued HR manager Eric Stevens for defamation based on statements to union officers and a deputy sheriff.
- District court granted summary judgment for CTC, the Union, and Stevens; the Sixth Circuit affirmed, holding the Union’s representation was not arbitrary/ discriminatory/ in bad faith, and Stevens’ statements were true or privileged.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Union breached its duty of fair representation (hybrid §301) | Union failed to reasonably investigate, excluded Blesedell from process, and declined arbitration despite his request | Union reasonably investigated, considered evidence, involved grievant adequately, and legitimately concluded arbitration would fail | Union did not breach duty; summary judgment for Union affirmed |
| Whether Union conduct was arbitrary | Investigation missed key witness interviews and withheld grievant’s affidavits, showing irrational conduct | Union reviewed GPS, recordings, timecards and affidavits; decisions were within a wide range of reasonableness | Not arbitrary; union actions were reasonable |
| Whether Union acted discriminatorily or in bad faith | Union treated Blesedell differently and had improper motives (personal/management ambitions) | No evidence of intentional, severe, unexplained discrimination or malice; decisions tied to legitimate objectives | No discrimination or bad faith shown |
| Whether Stevens’ statements were defamatory | Stevens told union/officers and a deputy that Blesedell had been fired for allegations including selling parts for drugs and that Blesedell had modified ticket — harms reputation | Statements were true, fair report of allegations, or protected by qualified privilege; no actual malice | Statements were true or privileged; summary judgment for Stevens affirmed |
Key Cases Cited
- Garrison v. Cassens Transp. Co., 334 F.3d 528 (6th Cir. 2003) (hybrid §301/fair-representation legal standard)
- Vaca v. Sipes, 386 U.S. 171 (U.S. 1967) (union duty of fair representation framework)
- Black v. Ryder/P.I.E. Nationwide, Inc., 15 F.3d 573 (6th Cir. 1994) (failure to interview a key witness can show breach when it likely affected outcome)
- Air Line Pilots Ass’n v. O’Neill, 499 U.S. 65 (U.S. 1991) (arbitrariness defined as conduct outside wide range of reasonableness)
- Walk v. P.I.E. Nationwide, Inc., 958 F.2d 1323 (6th Cir. 1992) (union must undertake a reasonable, not error-free, investigation)
- Gen. Motors Corp. v. NLRB, 700 F.2d 1083 (6th Cir. 1983) (employer duty to provide union information relevant to grievance)