Clark-Williams v. Washington Metropolitan Area Transit Authority, 244 F. Supp. 3d 195

Background

Clark-Williams, a former WMATA bus driver, was terminated in 2011 and Local 689 (his union) negotiated a 2012 Settlement Agreement with WMATA providing for reinstatement conditioned on passing WMATA’s Background Screening Policy.
Clark-Williams had disclosed a prior New Jersey criminal record at hire; Local 689’s shop steward (Garland) allegedly told him that disclosure would not prevent reinstatement (Garland disputes this).
WMATA’s Background Screening Policy treats returning employees seeking reinstatement as "external candidates," subjects them to a national criminal-history screen, and lists certain felony convictions (including assault and receiving stolen property) as permanent disqualifiers; Appendix D’s exclusion for convictions disclosed on original applications applies only to internal candidates.
Clark-Williams failed the background check based on felony convictions and WMATA declined to reinstate him; Local 689 pursued arbitration, and the arbitration panel upheld WMATA’s application of the Policy and denial of reinstatement.
Clark-Williams sued WMATA and Local 689 in a hybrid § 301/fair-representation action, alleging (1) WMATA breached the CBA by applying the Background Screening Policy and by failing to take action against Garland, and (2) Local 689 breached its duty of fair representation.
The district court granted summary judgment to WMATA and Local 689, holding Clark-Williams failed to show WMATA breached the CBA (an essential element of his hybrid claim) and therefore both defendants were entitled to judgment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether WMATA breached the CBA by conditioning reinstatement on and applying its Background Screening Policy	Clark-Williams: conditioning reinstatement on the Policy and ignoring Appendix D (which excludes disclosed convictions) unlawfully led to his non-reinstatement	WMATA: the CBA reserves hiring/selection standards to WMATA; the Policy lawfully treats reinstatement candidates as external and does not invoke Appendix D for such candidates	Held: No breach — CBA §102(b) reserves selection standards to WMATA; Policy properly applied to returning employees as external candidates
Whether WMATA breached the CBA by failing to take action against union steward Garland for allegedly misleading Clark-Williams	Clark-Williams: WMATA should have taken action against Garland and that failure breached the CBA (allegedly harmed reinstatement)	Defendants: plaintiff offers no evidence or legal theory showing what duty in the CBA required WMATA to act or what action would have remedied harm	Held: No breach — plaintiff failed to adduce any evidence or specify contractual basis, so summary judgment for defendants
Whether Local 689 breached its duty of fair representation, allowing Clark-Williams to sue despite arbitration result	Clark-Williams: Local 689 failed to oppose/ prevent application of the Policy and mishandled the grievance/arbitration	Local 689: even if arbitration adverse, plaintiff must show both a breach of the CBA by WMATA and a union breach; plaintiff cannot prove CBA breach	Held: No relief — hybrid claim fails because Clark-Williams could not show WMATA breached the CBA, so Local 689 entitled to judgment as well

Key Cases Cited

DelCostello v. Int’l Bhd. of Teamsters, 462 U.S. 151 (1983) (establishes hybrid §301/fair-representation claim requiring proof of both employer breach of the CBA and union breach of the duty of fair representation)
Vaca v. Sipes, 386 U.S. 171 (1967) (explains standards for union duty of fair representation and arbitration remedies)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden-shifting principles)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (materiality and genuine dispute standards for summary judgment)
Malloy v. WMATA, 187 F. Supp. 3d 34 (D.D.C. 2016) (discusses hybrid §301/fair-representation framework in WMATA context)