Trent Renner v. Ford Motor Company
516 F. App'x 498
6th Cir.2013Background
- Renner began working for Ford in 1999 at the Sharonville, Ohio, transmission plant and faced a lengthy daily commute from Columbus Grove.
- CBA provided two paths to Lima transfers: quit-and-rehire with loss of seniority, or transfer via a posted opening preserving seniority, but no Lima postings materialized for years.
- UAW official Brett Fox and Ford official Jack Halverson allegedly arranged a transfer to Lima in 2006 with seniority preserved, though no posting existed, and Renner was later told he was a quit-and-rehire.
- Local 1219 Chair Dan Hinegardner filed a grievance in 2006 to restore Renner’s seniority; the grievance was denied because of the quit-and-rehire status.
- In 2009, during layoffs, the union and Ford resolved the 2006 grievance to restore Renner’s 1999 seniority; the 2009 resolution was subsequently reversed in 2010 by the UAW’s International Executive Board, prompting this hybrid §301 action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did UAW breach its duty of fair representation regarding the 2006 seniority loss? | Renner argues the 2006 deal violated the CBA and was handled with bad faith. | UAW acted in good faith to facilitate the transfer and preserve Renner’s pursuit of seniority. | No breach; no evidence of arbitrariness or bad faith. |
| Did UAW act arbitrarily or in bad faith in the 2009 restoration of seniority? | Restoration was part of an illicit backroom deal to favor Renner. | Restoration simply fulfilled prior promises to Renner and followed union procedures. | Unpreserved claim; even if considered, no bad faith shown; not arbitrary. |
| Was the 2010 IEB reversal of the 2009 grievance resolution arbitrary or in bad faith? | IEB reversal undermined Renner’s prior favorable resolution. | IEB concluded no contractual support for the seniority arrangement; reversal was reasoned and in good faith. | No arbitrariness or bad faith; decision within range of reason. |
Key Cases Cited
- Vaca v. Sipes, 386 U.S. 171 (U.S. 1967) (duty of fair representation requires proof of arbitrary, discriminatory, or bad-faith conduct)
- DelCostello v. Int'l Bhd. of Teamsters, 462 U.S. 151 (U.S. 1983) (hybrid §301 claim requires proving both employer breach and union breach)
- O'Neill (Air Line Pilots Ass'n v. O'Neill), 499 U.S. 65 (U.S. 1991) (high deference to union decisions within a wide range of reasonableness)
- Courie v. Alcoa Wheel & Forged Prods., 577 F.3d 625 (6th Cir. 2009) (unreasonableness not shown where union determines not to pursue meritless grievance)
- Merritt v. Int'l Ass'n of Machinists & Aerospace Workers, 613 F.3d 609 (6th Cir. 2010) (defining 'bad faith' and upholding deference to union conduct absent improper motive)