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UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE
UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS, INTERNATIONAL UNION, AFL-CIO-CLC, and UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS LOCAL 4-786, Plaintiffs, v. E.I. DuPONT De NEMOURS AND COMPANY, Defendant. ____________________________________/ Case No.
COMPLAINT FOR BREACH OF LABOR CONTRACT AND TO COMPEL LABOR ARBITRATION
Come now Plaintiffs United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers ("the International Union") and United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers, Local 4-786, ("Local 4-786"), and complain against Defendant E.I. DuPont De Nemours and Company ("DuPont").
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Introduction 1. This is a suit by labor organizations for breach of a collective
bargaining agreement and to compel an employer to process a grievance and participate in the arbitration of that grievance pursuant to the procedure in the parties' collective bargaining agreement which provides for grievances to be discussed in the grievance procedure and resolved by a labor arbitrator in final and binding arbitration. Jurisdiction and Venue 2. This Court has jurisdiction over this action under Section 301 of the
Labor Management Relations Act of 1947 ("LMRA"), 29 U.S.C. § 185, and under 28 U.S.C. §§ 1331 and 1337. 3. Venue is proper in this Court under 28 U.S.C. § 1391(b)(1) and (2).
The Parties and the CBA 4. Plaintiffs are labor organizations representing employees in
industries affecting commerce within the meaning of the LMRA, 29 U.S.C. §§142, 152, and 185, and represent employees within this judicial district, including DuPont employees in the collective bargaining unit at DuPont's plant in Edgemoor, Delaware, within this judicial district. Local 4-786 maintains its principal office in Edgemoor, Delaware. 5. Defendant DuPont is an employer engaged in an industry affecting
commerce within the meaning of the LMRA, 29 U.S.C. §§ 142, 152, and 185, doing business within this judicial district and operating a plant in Edgemoor, Delaware, whose employees include the represented collective bargaining unit.
2
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6.
The International Union and Local 4-786 and DuPont are parties to
a collective bargaining agreement applicable to that collective bargaining unit of employees at DuPont's Edgemoor plant consisting of "all employees . . . with the exception of the Administrative Secretary to the Plant Manager, Human Resources Assistant, Technologists (Training, Planning, DCS), Work Leader, Nurses, salary roll employees exempt under the Fair Labor Standards Act, and supervisory employees with the authority to hire, promote, discharge, discipline or otherwise effect changes in the status of employees or effectively recommend such action." Attached hereto as Exhibit A is a true copy of the collective bargaining agreement between the International Union and Local 4-786 and DuPont applicable to this bargaining unit, which collective bargaining agreement has an effective date of May 20, 2006, and is scheduled to expire on May 19, 2009. 7. Article VI, Section 1 of the collective bargaining agreement states:
"Definition of Grievance. During the term of this Agreement, a grievance is: (1) an allegation by an employee or the Union that the Plant has violated an express provision of this Agreement as defined in Section 3 of Article III; (2) any other dispute between the Plant and the Union or employees concerning terms or conditions of employment." Article VI, Section 2 of the collective bargaining agreement provides for a threestep grievance procedure prior to the submission of a grievance to arbitration. 8. Article VII, Section 1 of the collective bargaining agreement states:
"Any question as to the interpretation, or any alleged violation, of any provision of this Agreement, as defined in Section 3 of Article III, which is not otherwise settled to the mutual satisfaction of the parties hereto, at the request of either party, shall be submitted to arbitration in the manner provided in Section 2 of this Article." 3
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9.
On August 28, 2006, DuPont announced in an e-mail sent to all
United States employees various changes in terms and conditions of employment of members of the bargaining unit. Such changes were to become effective on January 1, 2007, for bargaining-unit members hired on or after that date and on January 1, 2008, for bargaining-unit members hired before January 1, 2007. A true copy of this announcement is attached as Exhibit B. 10. On September 14, 2006, Local 4-786 President Mark Schilling and
Vice-President Thomas M. Campbell filed Grievance No. 1867. A copy of Grievance No. 1867 is attached hereto as Exhibit C. Subsequently, Grievance No. 1867 was amended, and a true copy of the amended grievance is attached as Exhibit D. The amended grievance, which incorporated the August 28, 2006, announcement, stated in full: "On August 28, 2006, the Company announced changes in the terms and conditions of employment for actives and new hires in the attached e-mail incorporated herein, sent on that date to U.S. employees from Jim Borel, Senior Vice President Human Resources. With respect to actives, the application to such persons of the changes in the Pension and Retirement Plan and Savings and Investment Plan, effective January 1, 2008, violates Article IX, Section 1 of the Collective Bargaining Agreement because such changes are not permitted `modifications' within the meaning of that article and section. With respect to new hires hired on or after January 1, 2007, the withdrawal, effective January 1, 2007, of the Pension and Retirement Plan, and the current terms of the Vacation Plan, violate Article IX, Section 1 on two independent and sufficient grounds. First, these announced changes violate Article IX, Section 1, because such changes are not permitted `modifications' within the meaning of that Article and Section. Second, these announced changes involved `Company Plans and Practices' within the meaning of Article IX, Section 1 and their withdrawal from employees covered by this agreement, on and after January 1, 2007, violates Article IX, Section 1 because such Plans and Practices remain `in effect within the Company.' In addition, with respect to new hires hired on or after January 1, 4
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2007, the withdrawal of the subsidies for retiree health care (medical and dental) violates Article IX, Section 3 of the Collective Bargaining Agreement. Remedy: Cease and desist from making the announced changes. It is requested that the processing of this grievance, which has been filed as a precautionary measure, be held in abeyance pending the Company's response to the Union's pending information request." 11. On September 26, 2006, DuPont, in its First Step Response to the
grievance, inter alia, "agree[d] to suspend the grievance submission time limits (Article VI, Section 1 of the Collective Bargaining Agreement)" until a pending Union information request had been sufficiently answered. A true copy of DuPont's First Step Response is attached as Exhibit E. 12. On January 25, 2007, DuPont Human Resources Consultant Frank
Ingraham provided a memorandum, bearing that date, to Local Union President Schilling. In that memorandum, DuPont refused to process Grievance No. 1867 through the grievance and arbitration procedure and stated that "DuPont is not contractually obligated to submit the above-referenced grievance to arbitration, and DuPont hereby refuses to submit the disputes to arbitration." A true copy of this memorandum is attached as Exhibit F. In that same memorandum, Mr. Ingraham asserted that any claim by the Union or an individual must be submitted to the internal plan review procedures established pursuant to ERISA, which procedures designated DuPont as the final decision maker. 13. On February 8, 2007, United Steelworkers Senior Associate
General Counsel Richard J. Brean sent a certified letter to Mr. Ingraham. A true copy of this letter is attached as Exhibit G. In the letter, Mr. Brean stated that 5
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"The grievance is clearly arbitrable under the broadly worded arbitration clause of the CBA pursuant to §301 of the Labor Management Relations Act and is not subject to any exhaustion requirement applicable to individual eligibility claims under ERISA" and further stated that unless DuPont provided written notice within 10 days of the date of the letter that it had agreed to resume processing the grievance that suit would be brought in Federal District Court to compel it to do so. 14. On February 28, 2007, DuPont Corporate Counsel Laura H.
Huggett faxed a letter to Mr. Brean, dated February 27, 2007, a true copy of which is attached as Exhibit H. In that letter, Ms. Huggett reiterated DuPont's refusal to process the grievance to arbitration, stating that "DuPont does not believe the Union's grievances are arbitrable because they inevitably involve benefit eligibility determinations that must be resolved under the claims procedures set forth in the specific ERISA benefit plans under which eligibility for benefits is being asserted or in a civil action under ERISA." She did so notwithstanding that DuPont in her letter disputed the arbitrability under the terms of the collective bargaining agreement of only that limited portion of the grievance involving a dispute under either the Medical Care Assistance Plan or the Dental Assistance Plan.
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DuPont's Breach and This Suit to Compel Arbitration 15. By refusing to process Grievance No. 1867 through the grievance
procedure and to further process the grievance to arbitration, DuPont has breached and continues to breach the collective bargaining agreement since Grievance No. 1867 is both grievable and arbitrable under the provisions of Article VI, Section 1 and Article VII, Section 1 of the collective bargaining agreement. 16. By refusing to cooperate or participate in the processing and
arbitration of the grievance and breaching the collective bargaining agreement, DuPont is undermining the collective bargaining relationship and causing harm and damage to the International Union and Local 4-786 and represented employees in the collective bargaining unit. 17. The claims set forth the in Grievance No. 1867 are not subject to
any internal plan review procedures established pursuant to ERISA. 18. The Union and Local 4-786 ask that this Court find DuPont to be in
breach of the collective bargaining agreement and compel DuPont to process Grievance No. 1867 through the grievance procedure and arbitrate said grievance. WHEREFORE, Plaintiffs International Union and Local 4-786 pray that this Court: 1. Enter judgment in their favor and against Defendant DuPont,
finding that DuPont breached and continues to breach the collective bargaining agreement;
7
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Free Complaint - District Court of Delaware - Delaware
| File Size: | 3,848.8 kB |
| Pages: | 141 |
| Date: | September 8, 2008 |
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| State: | Delaware |
| Category: | District Court of Delaware |
| Author: | unknown |
| Word Count: | 3,673 Words, 21,016 Characters |
| Page Size: | Letter (8 1/2" x 11") |
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