Krista Jones v. Interlake Steamship Co.

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 27, 2025
Docket24-1435
StatusUnpublished

This text of Krista Jones v. Interlake Steamship Co. (Krista Jones v. Interlake Steamship Co.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Krista Jones v. Interlake Steamship Co., (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0039n.06

No. 24-1435

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jan 27, 2025 KRISTA JONES, ) KELLY L. STEPHENS, Clerk Plaintiff-Appellant, ) ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT COURT FOR THE WESTERN INTERLAKE STEAMSHIP COMPANY; MARINE ) DISTRICT OF MICHIGAN ENGINEERS’ BENEFICIAL ASSOCIATION, ) DISTRICT 1-PCD, ) ) OPINION Defendants-Appellees. )

Before: KETHLEDGE, THAPAR, and LARSEN, Circuit Judges.

KETHLEDGE, Circuit Judge. Krista Jones appeals the district court’s grant of summary

judgment to the Marine Engineers’ Beneficial Association, and its denial of her motion to amend

her complaint. We reject her arguments and affirm.

I.

In March 2018, Interlake Steamship Company assigned Krista Jones to work as the chief

steward (head cook) aboard the Stewart J. Cort—a 1,000-foot freighter that routinely carries iron

ore from the far western end of Lake Superior to Chicago. As chief steward, Jones prepared the

crew’s meals, supervised the ship’s kitchen staff, and was a dues-paying member of the union for

Interlake’s supervisory officers, namely the Marine Engineers’ Beneficial Association.

On May 29, 2019, the Cort was taking on ore in Superior, Wisconsin. Jones worked that

day from 7:00 a.m. until roughly 5:40 p.m. Although the ship was scheduled to leave at 6:00 p.m.,

a crew member told Jones that loading the ship would take another hour and a half. Jones then left No. 24-1435, Jones v. Interlake Steamship, Co.

the ship to run an errand on shore and returned just before 7:00 p.m.—by then the ship had

departed. Interlake fired her the next morning.

On May 31, Jones called the union and demanded that they challenge her termination.

Union officials told her there was nothing they could do because she had missed the ship. In late

June, Jones requested a copy of the union’s collective-bargaining agreement, for which she paid a

$25 processing fee. That agreement stated that most union members could be terminated only for

just cause, and that the union could arbitrate whether a member’s termination had violated that

clause. But Jones found that a “side letter” to the agreement excluded chief stewards (and captains)

from these rights. Thus, under the agreement, Interlake could terminate Jones at will—despite her

union membership.

Jones nonetheless pressured the union to act. In July, Jason Callahan, the union’s vice

president, investigated her allegations but found she lacked a basis to challenge her termination.

Callahan therefore refused to seek arbitration of Jones’s claim. A month later, the union’s “district-

executive committee” reached the same conclusion.

Jones thereafter sued both Interlake and the union in state court, claiming (under both

federal and state law) that Interlake had breached the collective-bargaining agreement by firing

her without just cause. Jones also claimed the union had breached its duty of fair representation

by refusing to arbitrate her claims against Interlake and by having agreed to classify chief stewards

as at-will employees through the side letter. In December 2019, Interlake removed the case to

federal court; Jones then amended her complaint to add a claim against the union for charging her

$25 for a copy of the collective-bargaining agreement.

Interlake later moved to dismiss, and the union moved for summary judgment. The district

court construed Jones’s claims against the union and Interlake, regarding her termination, as a

-2- No. 24-1435, Jones v. Interlake Steamship, Co.

“hybrid” claim under Section 301 of the Labor Management Relations Act. 29 U.S.C. § 185(a).

The court dismissed that claim against both defendants, because Jones had not plausibly alleged

that Interlake had breached the collective-bargaining agreement. See, e.g., Swanigan v. FCA US

LLC, 938 F.3d 779, 784 (6th Cir. 2019). The court dismissed as time-barred Jones’s standalone

fair-representation claim regarding the union’s agreement to the side letter. The court also

dismissed Jones’s processing-fee claim—holding that the union could collect a “modest printing

charge” for copies of a collective-bargaining agreement. Finally, the court dismissed as preempted

her state-law claims against both defendants.

Jones appealed that order in December 2020. We affirmed the dismissal of the state claims

and the hybrid Section 301 claim against both the union and Interlake. But we reversed on Jones’s

standalone fair-representation and processing-fee claims against the union, and remanded those

claims to the district court.

On remand, Jones sought to bring Interlake back into the case by filing a motion to amend

the complaint—but the court denied that motion as futile. The union, for its part, sought to resolve

the processing-fee claim by paying Jones $50. Rather than seek to dismiss that claim voluntarily,

however, Jones moved for summary judgment as to that claim and requested attorney fees. The

court granted summary judgment to Jones, but denied without prejudice her request for attorney

fees. The union later moved for summary judgment on Jones’s standalone fair-representation

claim. The court granted that motion, and Jones brought this appeal.

II.

We review the district court’s grant of summary judgment de novo. Walden v. General

Electric Int’l, Inc., 119 F.4th 1049, 1056 (6th Cir. 2024).

-3- No. 24-1435, Jones v. Interlake Steamship, Co.

Unions must fairly represent their members in contract negotiations. See Air Line Pilots

Ass’n, Intern. v. O’Neill, 499 U.S. 65, 67 (1991). A union breaches this duty when its “conduct

toward a member of the collective bargaining unit is arbitrary, discriminatory, or in bad faith.”

Vaca v. Sipes, 386 U.S. 171, 190 (1967). Here, Jones contends that the union acted arbitrarily—

by agreeing to terms that classified chief stewards as at-will employees.

“[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.” O’Neill, 499 U.S. at 67 (citation omitted). Under this standard, a union’s

conduct can favor one group over another as long as the union’s “actions are related to legitimate

union objectives.” Bondurant v. Air Line Pilots Ass’n, 679 F.3d 386, 393 (6th Cir. 2012).

Here, by way of background, Interlake had no obligation under federal law to bargain with

the union at all regarding the supervisors on Interlake’s ships. See 29 U.S.C. § 164(a); Florida

Power & Light Co. v. Int’l Bhd. of Elec. Workers, Loc. 641, 417 U.S. 790, 808 (1974). Interlake

used that leverage, in negotiations with the union, to propose that captains and chief stewards be

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Vaca v. Sipes
386 U.S. 171 (Supreme Court, 1967)
Air Line Pilots Ass'n v. O'Neill
499 U.S. 65 (Supreme Court, 1991)
Marquez v. Screen Actors Guild, Inc.
525 U.S. 33 (Supreme Court, 1998)
Bondurant v. Air Line Pilots Ass'n, International
679 F.3d 386 (Sixth Circuit, 2012)
JPMorgan Chase Bank, N.A. v. Larry J. Winget
920 F.3d 1103 (Sixth Circuit, 2019)
Beverly Swanigan v. FCA
938 F.3d 779 (Sixth Circuit, 2019)
Hobart-Mayfield, Inc. v. NOCSAE
48 F.4th 656 (Sixth Circuit, 2022)
Michael Walden v. General Electric Int'l
119 F.4th 1049 (Sixth Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Krista Jones v. Interlake Steamship Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/krista-jones-v-interlake-steamship-co-ca6-2025.