The Hawaii Intermediate Court of Appeals recently ruled in favor of the University of Hawaii (UH) in a labor dispute involving former employees and their union representation. The court's decision affects the claimants, who previously held temporary positions at UH, and raises important questions about labor relations and union responsibilities.

This case stems from a grievance filed by eight former UH employees against the Hawaii Government Employees Association (HGEA) and UH itself. The claimants argued that their union failed to represent them adequately when they were terminated early from their positions. The court's ruling has significant implications for labor relations in Hawaii, particularly regarding how unions handle grievances.

Background

The parties involved in this case include the University of Hawaii as the respondent-appellant and the Hawaii Labor Relations Board (HLRB) as the agency-appellee. The claimants, Lenora L. Asato, Jennifer E. Halaszyn, Jeff Ibara, Yoshiaki Iinuma, Charles Luk, Joy Magarifuji, Siiri Aileen Wilson, and Gang Yuan, were all members of HGEA Bargaining Unit 8 (BU8) and held temporary positions in UH's Office of Research Services.

The dispute began when the claimants were informed in July 2017 that they would be terminated from their positions on December 31, 2017, despite their contracts having an end date of June 30, 2018. They filed a grievance under the collective bargaining agreement (CBA) with UH, claiming that the university's actions were unjust. However, the HGEA declined to take the grievance to arbitration, leading the claimants to file a prohibited practice complaint against the union with the HLRB in September 2018.

As the case progressed, the claimants amended their complaint to include UH as a respondent, alleging that the university violated state labor laws by allowing a union member to represent them in the grievance process. The HLRB ultimately ruled that the HGEA did not breach its duty of fair representation, which prompted UH to appeal the decision to the circuit court.

The Ruling

On September 22, 2026, the Hawaii Intermediate Court of Appeals issued its ruling, reversing the circuit court's Final Judgment that had affirmed the HLRB's Decision No. 517. The court determined that the HLRB's proceedings constituted a hybrid action, meaning that the claimants needed to prove both that the union breached its duty of fair representation and that UH violated the CBA.

The court ruled, "The HLRB determined that HGEA did not breach its duty of fair representation. No one challenges that ruling. Once the HLRB made that determination, it should have dismissed the amended complaints against UH."

The ruling was made by Presiding Judge Keith K. Hiraoka, along with Associate Judges Sonja M.P. McCullen and Kimberly T. Guidry. The court found that the claimants failed to prove their case against HGEA, and therefore, the complaints against UH should have been dismissed.

Impact

This ruling has significant implications for labor relations in Hawaii. It clarifies the responsibilities of unions in representing their members and sets a precedent for how similar cases may be handled in the future. The court's decision emphasizes that if a union is found not to have breached its duty of fair representation, then claims against the employer related to that grievance may also be dismissed.

The outcome affects not only the claimants but also other employees in similar situations who may seek recourse through their unions. It underscores the importance of unions fulfilling their obligations to represent their members effectively, as failure to do so could prevent employees from pursuing claims against their employers.

What's Next

The court's decision can be appealed, but it is unclear whether the claimants will pursue further legal action. There are no related cases pending at this time. The ruling serves as a reminder of the complexities involved in labor relations and the critical role unions play in protecting employee rights.