Principles of fair representation assignment

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Principles of Fair Representation

To prepare for this assignment, please read Garcia v. Salt River Project Agric. Improvement & Power Dist., 618 F. Supp. 2d 1092 (D. Ariz. 2007)

  • Please review the six (6) principles set forth, afterward, explain how, if at all, they manifest themselves in the Garcia case.
  • Your response to the questions should, in total, be 750 words or less.

Diana L. Garcia, Plaintiff, vs. Salt River Project Agricultural Improvement and
Power District; International Brotherhood of Electrical Workers Local Union 266,

John Does I-V and Jane Does I-V; Black Corporations I-III and White Partnerships
I-III, Defendants.

No. CV-05-1279-PHX-ROS

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

618 F. Supp. 2d 1092; 2007 U.S. Dist. LEXIS 98440

September 30, 2007, Decided

PRIOR HISTORY: Garcia v. Salt River Project Agric.
Improvement & Power Dist., 2006 U.S. Dist. LEXIS
54871 (D. Ariz., Aug. 4, 2006)

COUNSEL: [**1] For Diana L Garcia, a single woman,
Plaintiff: Angela Marie Wilson-Goodman, LEAD
ATTORNEY, Wilson-Goodman & Fong PC, Gilbert,
AZ.

For Salt River Project Agricultural Improvement and
Power District, a political subdivision of the State of
Arizona, Defendant: John James Egbert, LEAD
ATTORNEY, Jennings Strouss & Salmon PLC, Collier
Ctr, Phoenix, AZ.

For Local 266 International Brotherhood of Electrical
Workers, Defendant. Stanley Lubin, LEAD
ATTORNEY, Lubin & Enoch PC, Phoenix, AZ

JUDGES: Roslyn O. Silver, United States District Judge.

OPINION BY: Roslyn O. Silver

OPINION

[*1094] ORDER

Pending are various defense motions. The Court will

deny SRP’s motions to strike, will grant in part and deny
in part SRP’s Motion for Summary Judgment, and will
grant the Union’s Motion for Summary Judgment.

BACKGROUND

The following facts are not disputed. In 1987, the
Plaintiff, Diana L. Garcia (a hispanic woman), was hired
by Salt River Project Agricultural Improvement and
Power District (“SRP”) (SRP SOF P 1). Plaintiff held
various positions with SRP until she became a
Tradeshelper in 1994 (SRP SOF P 2). Later, in 1999, she
was promoted to the position of Equipment Operator II, a
position in which Plaintiff operated mobile cranes (SRP
SOF P 3). On April 27, 2004, while Plaintiff was
operating a crane to replace a transformer in a mobile
park, the crane tipped over and [*1095] crashed [**2]
into two mobile homes (SRP SOF P 5).

An SRP investigation determined that the crane
accident was preventable. The mobile crane had four
stabilizing legs called “outriggers” on the corners of the
bed of the truck that can be extended out six feet from the
truck (SRP SOF P 16). Plaintiff was trained that by fully
extending the outriggers the stability of the crane is
maximized and to use larger pads on the outriggers
whenever the ground was questionable in any way (SRP
SOF P 16, 18). 1 Plaintiff also understood that, as the
Equipment Operator, she had full authority not to go

Page 1

forward with a lift that she felt was unsafe or improper
and that she had full authority to tell her supervisor that
the lift was unsafe and should not proceed (SRP SOF P
24-25).

1 The operator’s manual for the crane, which
Plaintiff was expected to read and follow, also
instructs that “[t]he outriggers shall be fully
extended . . . before operating the boom” and that
“[i]t may be necessary to provide additional
support under the outrigger floats to spread the
load over a larger bearing surface” (SRP SOF P
22, 26).

When Mike Kirby (a white male), foreman of the
crew on which Plaintiff was working on April 27th,
directed [**3] the set up of the crane in preparation to
replace the transformer the two front outriggers were not
fully extended (PSOF P 1-2; SRP SOF P 38). Plaintiff
was in agreement with the way the crane was set up (SRP
SOF P 40). Further, while three of the outriggers were
placed on asphalt or concrete, the right rear outrigger was
placed on dirt (SRP SOF P 39). The larger pad was not
used to increase the stability of the right rear outrigger
placed on the dirt (SRP SOF P 57). When Plaintiff began
lowering the transformer to its destination, the right rear
outrigger sunk into the ground and the crane crashed into
the mobile homes (PSOF P 20). An SRP investigation
revealed that the cause of the accident was failure to
properly extend the outriggers and set them on solid
footing (PSOF P 25).

Representatives from the International Brotherhood
of Electrical Workers Local Union 266 (“Union”) were
present during much of the investigatory process.
Following the accident, SRP interviewed all the
employees who witnesses the accident, including Plaintiff
(Union’s SOF P 4). A Union representative was present
during these interviews (Union’s SOF P 4). A Union
representative also talked with Plaintiff and [**4] took
photos of the crane after the accident (Union’s SOF P 6).
At an SRP interview at which a Union representative was
present, Plaintiff stated: “I take full responsibility for the
operation of that vehicle” (Union’s SOF P 8). However,
Plaintiff later clarified that she accepted responsibility for
the operation of the crane, not the entire accident (SRP
SOF P 74). A Union representative also consulted other
crane operators who advised the Union that the crane was
not set up properly (Union’s SOF P 9).

After SRP reviewed the causes of the crane accident

and Plaintiff’s history of prior accidents, it initially
decided to terminate Plaintiff’s employment as a result of
the crane accident (SRP SOF P 71). SRP considered in
making its decision that, prior to this accident, Plaintiff
was involved in three other accidents which SRP had
previously determined to be preventable: she backed an
SRP truck into a building at a car dealership in 1998 and
she ran into a card reader for a gated entrance to an SRP
facility in both 2000 and 2001 (SRP SOF P 7, 66). After
the 2001 accident, Plaintiff was formally disciplined and
warned that any further accidents could result in further
discipline, including [**5] discharge (SRP SOF P 66).
Plaintiff presented evidence that fourteen [*1096] other
males with a total of 64 SRP Safety Code violations were
never discharged for their behavior (PSOF P 31).

At the urging of the Union on Plaintiff’s behalf and
with the Union’s consent, SRP agreed to allow Plaintiff to
choose demotion to her prior position of Tradeshelper in
lieu of termination (SRP SOF P 72). Under the terms of
the demotion option, Plaintiff could have later become
eligible to bid back up to higher-rated positions,
including that of an Equipment Operator, as long as she
did not operate a crane (Union’s SOF P 14). The Union
determined that the demotion offer was the best that it
could do to minimize the disciplinary action (Union’s
SOF P 12). The foreman, Mr. Kirby, received a written
reminder as discipline for his part in the accident, in
which he was placed on probation for 18 months (PSOF
P 30).

Plaintiff rejected the demotion option and her
employment with SRP was terminated on May 3, 2004
(SRP SOF P 9-10). After Plaintiff was discharged, the
Union filed a formal grievance on May 4, 2004, but later
withdrew it because the Union did not feel the grievance
had merit (Union’s SOF P 17). Plaintiff [**6] filed her
charge of discrimination with the EEOC on August 9,
2004 (SRP SOF P 84). Subsequently, on December 13,
2004, Plaintiff filed suit against SRP alleging
discrimination and hostile work environment. Plaintiff
alleges that she was subject to a hostile work
environment because of her gender, race, and national
origin from the time she began working with SRP in
1987 until October 2003. (See PSOF P 34-45; SRP SOF
P 76-77). Plaintiff also brought suit against the Union
alleging breach of the duty of fair representation and
breach of contract.

ANALYSIS

Page 2
618 F. Supp. 2d 1092, *1095; 2007 U.S. Dist. LEXIS 98440, **2

I. Jurisdiction

Plaintiff has brought this suit pursuant to Title VII of
the Civil Rights Act of 1964. The Court has federal
question jurisdiction. 28 U.S.C. § 1331. And the Court
has jurisdiction over Plaintiff’s state law claims pursuant
to the supplemental jurisdiction statute. 28 U.S.C. § 1367.

II. Motions to Strike

SRP moves to strike “evidence that 14 males with 64
total violations of Defendant SRP’s Safety Code were
never discharged for their behavior,” which was included
in Plaintiff’s Statement of Facts. SRP also moves to strike
Plaintiff’s thirteenth supplemental disclosure statement
which discloses this information. 2 SRP seeks [**7] to
strike this evidence because these 14 males were not
identified before the discovery deadline in response to an
SRP interrogatory which requested Plaintiff to “[i]dentify
all SRP employees whom you claim were similarly
situated to you, but were treated more favorably by SRP.”
(Doc. 162, Ex. A.)

2 SRP’s motions to strike are more properly
characterized as an objection to the use of
evidence. See Fed. R. Civ. P. 37(c)(1).

However, in Plaintiff’s Response to SRP’s Motion for
Summary Judgment, she does not argue that these 14
males are similarly situated. Rather, Plaintiff uses this
evidence to argue that her firing was a pretext for
discrimination. (See P’s Resp. to MSJ at 12-13.) The
Court will not consider the evidence of the 14 males
when deciding whether similarly situated persons outside
the protected class were treated more favorably than
Plaintiff. 3 [*1097] Consequently, the Court will deny
SRP’s motions to strike.

3 Likewise, if Plaintiff was trying to introduce
the evidence of the 14 males to show that
similarly situated persons outside the protected
class were treated more favorably than herself, the
Court will not consider the evidence because this
information was not supplemented before [**8]
the end of the discovery deadline. See Fed. R.
Civ. P. 37(c)(1). Plaintiff’s failure to supplement
her interrogatory response would not be harmless.

III. Summary Judgment Standard

A court must grant summary judgment if the

pleadings and supporting documents, viewed in the light
most favorable to the non-moving party, “show that there
is no genuine issue as to any material fact and that the
moving party is entitled to a judgment as a matter of
law.” Fed. R. Civ. P. 56(c); see Celotex Corp. v. Catrett,
477 U.S. 317, 322-23, 106 S. Ct. 2548, 91 L. Ed. 2d 265
(1986). Substantive law determines which facts are
material, and “[o]nly disputes over facts that might affect
the outcome of the suit under the governing law will
properly preclude the entry of summary judgment.”
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106
S. Ct. 2505, 91 L. Ed. 2d 202 (1986). In addition, the
dispute must be genuine, that is, “the evidence is such
that a reasonable jury could return a verdict for the
nonmoving party.” Anderson, 477 U.S. at 248.

Furthermore, the party opposing summary judgment
“may not rest upon the mere allegations or denials of [the
party’s] pleading, but . . . must set forth specific facts
showing that there is a genuine issue for trial.” Fed. R.
Civ. P. 56(e); [**9] see Matsushita Elec. Indus. Co., Ltd.
v. Zenith Radio Corp., 475 U.S. 574, 586-87, 106 S. Ct.
1348, 89 L. Ed. 2d 538 (1986). There is no issue for trial
unless there is sufficient evidence favoring the
non-moving party; “[i]f the evidence is merely colorable,
or is not significantly probative, summary judgment may
be granted.” Anderson, 477 U.S. at 249-50 (citations
omitted). However, “[c]redibility determinations, the
weighing of the evidence, and the drawing of legitimate
inferences from the facts are jury functions, not those of a
judge.” Id. at 255. Therefore, “[t]he evidence of the
non-movant is to be believed, and all justifiable
inferences are to be drawn in [its] favor” at the summary
judgment stage. Id. Finally, Rule 56(e) contemplates the
result of a party’s failure to respond adequately to a
motion for summary judgment. If the non-moving party
does not respond by setting forth specific facts showing
there is a genuine issue for trial, “summary judgment, if
appropriate, shall be entered against the [non-moving]
party.” Fed. R. Civ. P. 56(e).

III. Disparate Treatment Claim Against SRP

Plaintiff alleges that SRP targeted Plaintiff for more
severe punishment due to her gender, race, and national
origin. Specifically, [**10] Plaintiff argues that she
received disparate treatment because she was subjected to
greater punishment than Mr. Kirby.

The proper legal framework for determining whether
Plaintiff’s disparate treatment claim should survive

Page 3
618 F. Supp. 2d 1092, *1096; 2007 U.S. Dist. LEXIS 98440, **6

summary judgment is the burden shifting scheme:
Plaintiff must establish a prima facie case of
discrimination; if Plaintiff succeeds in establishing a
prima facie case, the burden of production shifts to SRP
to articulate a legitimate, nondiscriminatory reason for
terminating Plaintiff’s employment; and if SRP does so,
Plaintiff must demonstrate that SRP’s articulated reason is
a pretext for unlawful discrimination by “either directly
persuading the court that a discriminatory reason more
likely motivated the employer or indirectly by showing
that the [*1098] employer’s proffered explanation is
unworthy of credence.” Aragon v. Republic Silver State
Disposal Inc., 292 F.3d 654, 658-659 (9th Cir. 2002)
(citations and internal quotations omitted).

To establish a prima facie case for her claim,
Plaintiff must show that (1) she belongs to a protected
class, (2) she was qualified for the position, (3) she was
subject to an adverse employment action, and (4)
similarly situated persons [**11] outside the protected
class were treated more favorably. Aragon, 292 F.3d at
658. Here, the first three elements are clearly met.
However, Plaintiff cannot establish a prima facie claim of
disparate treatment because Mr. Kirby was not similarly
situated.

“In order to show that the ’employees’ allegedly
receiving more favorable treatment are similarly situated .
. ., the individuals seeking relief must demonstrate, at the
least, that they are similarly situated to those employees
in all material respects.” Moran v. Selig, 447 F.3d 748,
755 (9th Cir. 2006). For example, in Moran, the
plaintiffs, Major League Baseball (“MLB”) players who
had played less than the number of years required to vest
certain benefits, argued that they were similarly situated
to former Negro League players who had also played less
than the required number of years, but who received the
benefits. Id. Although the court noted that there were
some similarities, it found that the plaintiffs were not
similarly situated in all material respects because they
were “never prevented from playing for a MLB team, and
thus unable to acquire the necessary longevity.” Id.
Moreover, the plaintiffs never played in the Negro
Leagues, [**12] a primary requirement for eligibility
under the Negro League Plans. Id.

Like the plaintiffs in Moran, Plaintiff is not similarly
situated in all material respects to Mr. Kirby. A major
consideration in SRP’s decision to terminate Plaintiff’s
employment was her history of preventable accidents.

Prior to the crane accident, Plaintiff was formally
disciplined and expressly warned that any further
accidents could result in termination. Plaintiff has
presented no evidence of prior safety violations or
preventable accidents for Mr. Kirby. Further, Plaintiff
and Mr. Kirby had different responsibilities. Mr. Kirby as
foreman had overall responsibility for the safe
completion of the job and to oversee the work of all the
members of the crew. Plaintiff’s responsibility was
limited to the operation of the crane. While the parties
contest whether Plaintiff was more responsible for the
accident than Mr. Kirby, Plaintiff has presented no
evidence about whether SRP has ever disciplined a
foreman with general responsibility more or less than an
employee with specific responsibility. Accordingly, the
Court will grant summary judgment in favor of SRP on
the Plaintiff’s disparate treatment claim.

IV. Hostile [**13] Work Environment Claim against
SRP

Plaintiff based her hostile work environment claim
on several incidents that occurred over her 17 years of
employment with SRP. “In determining whether an
actionable hostile work environment claim exists, [the
courts] look to all the circumstances, including the
frequency of the discriminatory conduct; its severity;
whether it is physically threatening or humiliating, or a
mere offensive utterance; and whether it unreasonably
interferes with an employee’s work performance.”
National R.R. Passenger Corp. v. Morgan, 536 U.S. 101,
116, 122 S. Ct. 2061, 153 L. Ed. 2d 106 (2002) (internal
quotations omitted). Acts occurring more than 300 days
from the date a claimant filed a claim with the Equal
Employment Opportunity [*1099] Commission are time
barred if the act is unrelated to the unlawful employment
practice that occurred within the 300 day limitation
period. Id. at 117-18.

In the present case, Plaintiff filed her charge of
discrimination with the EEOC on August 9, 2004.
Therefore, the 300 day limitation period only extends
back to acts occurring on or after October 14, 2003.
Plaintiff alleged that a crew leader called Plaintiff
derogatory names on more than on occasion in October
of 2003. However, [**14] Plaintiff has alleged no other
incidents that occurred within the 300 day limitation
period. In its motion for summary judgment, SRP argued
that the other incidents alleged by Plaintiff, which fell
outside the 300 day limitation period, are barred because

Page 4
618 F. Supp. 2d 1092, *1097; 2007 U.S. Dist. LEXIS 98440, **10

they are unrelated to these name calling incidents in
October of 2003. Further, SRP argued that the name
calling incidents, by themself, are insufficient to establish
a hostile work environment claim. Plaintiff failed to
specifically respond to these arguments in her response to
SRP’s Motion for Summary Judgment.

Generally, a party’s failure to respond to arguments
in a motion “may be deemed consent to the denial or
granting of the motion and the Court may dispose of the
motion summarily.” Local Rule 7.2(i). However, in the
factual summary included in Plaintiff’s Response she
includes a section entitled, “Plaintiff’s Discriminatory and
Hostile Experiences While Employed by Defendant
SRP.” (See P’s Resp. at 5-6.) Based on this, it is unclear
whether Plaintiff has abandoned her hostile work
environment claim. Accordingly, the Court will allow
Plaintiff to file a supplemental response for the specific
and limited purpose of addressing [**15] the arguments
raised by SRP regarding her hostile work environment
claim.

V. Breach of Duty of Fair Representation Claim
against the Union

Both parties agree that the Union owes a duty of fair
representation to Plaintiff governed by federal labor
statutes. (See Union’s MSJ at 8-9; P’s Resp. at 5-6).
Plaintiff alleges that the Union breached its duty of fair
representation because Plaintiff was subject to more
severe disciplinary action than Mr. Kirby and the 14 other
males, and the Union failed to perform “any sort of
investigation into the accident.”

The duty of fair representation requires a union to
“serve the interests of all members without hostility or
discrimination toward any, to exercise its discretion with
complete good faith and honesty, and to avoid arbitrary
conduct.” Vaca v. Sipes, 386 U.S. 171, 177, 87 S. Ct. 903,
17 L. Ed. 2d 842 (1967). A union breaches this duty only
if its “conduct toward a member of the collective
bargaining unit is arbitrary, discriminatory, or in bad
faith.” Id. at 190. A union’s conduct is arbitrary only if “it
is irrational, when it is without a rational basis or
explanation.” Marquez v. Screen Actors Guild, Inc., 525
U.S. 33, 46, 119 S. Ct. 292, 142 L. Ed. 2d 242 (1998);
see also Air Line Pilots Ass’n, Int’l v. O’Neill, 499 U.S.
65, 67, 111 S. Ct. 1127, 113 L. Ed. 2d 51 (1991) [**16]
(“[A] union’s actions are arbitrary only if, in light of the
factual and legal landscape at the time of the union’s
actions, the union’s behavior is so far outside a ‘wide

range of reasonableness,’ . . . as to be irrational.”). Mere
negligence in carrying out the duty of fair representation
does not constitute a breach of the duty of fair
representation. United Steelworkers of America v.
Rawson, 495 U.S. 362, 372-73, 110 S. Ct. 1904, 109 L.
Ed. 2d 362 (1990).

“A union’s duty of fair representation includes the
duty to perform some minimal investigation, the
thoroughness of which [*1100] varies with the
circumstances of the particular case.” Evangelista v.
Inlandboatmen’s Union of Pacific, 777 F.2d 1390, 1395
(9th Cir. 1985). “[O]nly an egregious disregard for union
members’ rights” constitutes a breach of the duty of
investigation.” Castelli v. Douglas Aircraft Co., 752 F.2d
1480, 1483 (9th Cir. 1985). For example, in Eichelberger
v. NLRB, 765 F.2d 851, 857 (9th Cir. 1985), the court
found that a union’s investigation was adequate when the
union president merely read the grievant’s letter several
time before reaching the conclusion that further
investigation was unnecessary. In addition, “extensive
investigation by a union is [**17] unnecessary where it
would not have resulted in the development of additional
evidence which would have altered the decisions not to
pursue the grievance.” Evangelista, 777 F.2d at 1395-96.

The Union satisfied its duty of fair representation as
a matter of law. No reasonable finder of fact could find
that the Union acted so far outside the wide range of
reasonableness, when it negotiated with SRP to demote
Plaintiff in lieu of terminating Plaintiff, as to be
irrational. The crane accident was very serious and the
facts establish as a matter of law that at least part of the
responsibility for this accident rests on Plaintiff’s
shoulders. Before the Union’s involvement, SRP planned
on terminating Plaintiff. However, as a result of the
Union’s negotiations, Plaintiff could have kept her job
and later have been eligible to bid into the position of
Equipment Operator. This offer was not irrational.

Comparisons to other male employees do not show
that Plaintiff was treated unfairly. Plaintiff has not
presented any evidence that the Union negotiated on
behalf of Mr. Kirby or any of the other 14 males.
Moreover, as stated above, Plaintiff and Mr. Kirby were
not similarly situated–Plaintiff [**18] had a long history
of safety violations and held a different responsibility.
There is simply no evidence of invidious discrimination
on the part of the Union. See O’Neill, 499 U.S. at 81;
Simo v. Union of Needletrades, 322 F.3d 602, 618-19

Page 5
618 F. Supp. 2d 1092, *1099; 2007 U.S. Dist. LEXIS 98440, **14

(9th Cir. 2003).

The Union’s investigation also satisfied its obligation
of fair representation. It was present during interviews of
SRP employees who witnessed the accident; the Union
spoke with the Plaintiff; the Union took photos of the
crane; the Union consulted other crane operators; and the
Union considered Plaintiff’s own admission that she bore
responsibility for the operation of the crane. Given these
efforts, no reasonable fact finder could find that the
Union’s investigation was an egregious disregard of
Plaintiff’s rights.

Plaintiff contests that the “Union did nothing to
pursue the idea that the ground giving way was the cause
of the accident” (P’s Resp. to Union’s MSJ at 10).
However, Plaintiff offers no evidence which would show
the crane would not have crashed if it was properly set up
or that evidence of “the ground giving way” would have
altered the Union’s decision not to pursue the Plaintiff’s
grievance. See Evangelista, 777 F.2d at 1395-96 [**19]
(“[E]xtensive investigation by a union is unnecessary
where it would not have resulted in the development of
additional evidence which would have altered the
decisions not to pursue the grievance.”). Accordingly, the
Court will grant the Union’s motion for summary
judgment on Plaintiff’s fair representation claim.

VI. Breach of Contract Claim against the Union

Plaintiff claims the Union breached a contract
between her and the Union. However, Plaintiff presented
no evidence concerning which contract the Union
breached, the terms of the contract, or how the Union
[*1101] breached its terms. Plaintiff has not met her
burden of offering evidence to establish an issue of fact.
Thus, the Court will grant the Union’s motion for
summary judgment on Plaintiff’s breach of contract
claim.

Accordingly,

IT IS ORDERED SRP’s Motion to Strike re
Portions of Plaintiff’s Separate Statement of Facts (Doc. #
162) is DENIED.

IT IS FURTHER ORDERED SRP’s Motion to
Strike Plaintiff’s Thirteenth Supplemental Disclosure
Statement and Supplemental Responses to Interrogatories
(Doc. # 174) is DENIED.

IT IS FURTHER ORDERED SRP’s Motion for
Summary Judgment (Doc. # 145) is GRANTED IN
PART and DENIED IN PART. Plaintiff’s disparate
[**20] treatment claim is dismissed with prejudice.

IT IS FURTHER ORDERED Plaintiff may file a
supplemental response to SRP’s Motion for Summary
Judgment on Plaintiff’s hostile work environment claim
within 10 days of the date of this order. If Plaintiff files a
supplemental response, Defendant may have 10 days
after the date Plaintiff’s supplemental response to file a
supplemental reply.

IT IS FURTHER ORDERED the Clerk of the
Court dismiss Plaintiff’s case with prejudice if Plaintiff
fails to file a supplemental response within 10 days of the
date of this order.

IT IS FURTHER ORDERED the Union’s Motion
for Summary Judgment (Doc. # 147) is GRANTED.
Plaintiff’s case against the Union is DISMISSED WITH
PREJUDICE.

DATED this 30th day of September, 2007.

/s/ Roslyn O. Silver

Roslyn O. Silver

United States District Judge

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618 F. Supp. 2d 1092, *1100; 2007 U.S. Dist. LEXIS 98440, **18

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