Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT MARCUS PIERCE v. SCHWEBEL BAKING COMPANY; LOCAL 377 CHAUFFEURS TEAMSTERS WAREHOUSEMEN & HELPERS UNION ) ) ) ) ) ) ) ) ) ) ) ) ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-02

The Sixth Circuit affirmed the district court’s grant of summary judgment to the defendants in a hybrid § 301 Labor Management Relations Act claim, holding that the plaintiff failed to establish that the union breached its duty of fair representation. The court applied the standard that a union breaches this duty only if its conduct is arbitrary, discriminatory, or in bad faith, noting that the “duty of fair representation does not require that a union fully pursue every grievance filed.” Under the highly deferential “wide range of reasonableness” test, the court found the union’s decision not to arbitrate was not arbitrary because it conducted an independent investigation, consulted legal counsel regarding the low likelihood of success, and provided the employee an opportunity to present his case before the executive board. Because the plaintiff could not prove the union acted arbitrarily, he failed to satisfy the exhaustion requirement necessary to maintain his claim against the employer for wrongful termination. Consequently, the judgment in favor of the defendants stands, and the plaintiff’s claims are dismissed without a separate determination on whether the employer violated the collective bargaining agreement.

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