Note to Member: By signing this petition, members are exercising rights protected under the Union Constitution and applicable law. No member shall be subjected to any form of retaliation, adverse action, discrimination, intimidation, or harassment as a result of signing this petition. Any such conduct constitutes a violation of constitutional guarantees of free participation, due process, and fair representation and is subject to immediate corrective and disciplinary action.

We, the undersigned members of the Transportation Communications Union (TCU), formally demand the immediate review and removal of Katrina Coleman from her position within TCU National pursuant to the authority granted under the TCU National Constitution and Bylaws and under the protections afforded to union members under the Labor-Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. §401 et seq., including 29 U.S.C. §411.

This petition is submitted based upon serious and ongoing concerns regarding:

• Failure to uphold the duty of fair representation owed to members

• Lack of transparency in decision-making affecting membership

• Conduct inconsistent with fiduciary obligations to the union body

• Actions that have materially undermined member confidence

Members within the Northeast Corridor jurisdiction have been particularly affected and have experienced representation that appears compromised and inconsistent with the obligation to act solely in the best interests of dues-paying members.

Further, there are substantial concerns regarding the appearance of coordinated alignment between Katrina Coleman and Richard Funk, a company representative. One individual holds a position intended to advocate for union members; the other represents company interests. The perceived collaboration between these roles raises serious concerns regarding potential conflicts of interest and divided loyalty.

Even the appearance of impaired independence in representation undermines the integrity of union governance and erodes trust among the membership.

Katrina Coleman assumed office as National Representative over the Northeast Corridor in 2023, working in concert with Richard Funk upon his appointment as Superintendent of the Northeast Corridor, member employment terminations have increased at an alarming and unprecedented rate. These terminations appear to be motivated not by legitimate disciplinary standards or objective performance criteria, but by personal animus, retaliation, and selective enforcement directed at disfavored members.

This conduct constitutes a clear violation of the union’s Duty of Fair Representation, which legally and constitutionally requires the union to represent all members fairly, impartially, and in good faith, without discrimination, arbitrariness, or hostility. Rather than advocating on behalf of affected members, Ms. Coleman has failed to challenge management actions, declined to pursue grievances, and permitted or facilitated adverse employment actions against members based on personal bias and retaliatory intent.

Numerous complaints alleging retaliatory terminations, disparate treatment, and collusion between union leadership and management have been submitted to the National Office. Despite the seriousness of these allegations, the National Office has failed to investigate, intervene, or take corrective action. This prolonged inaction itself constitutes an additional breach of the Duty of Fair Representation, as it reflects deliberate indifference to member harm and a failure to enforce contractual and constitutional protections.

The apparent coordination between Ms. Coleman and Mr. Funk represents an impermissible alignment of union leadership with management interests, directly contrary to the union’s legal obligation to act exclusively in the interests of its members. Such conduct undermines grievance integrity, deprives members of meaningful representation, and violates fundamental labor-law principles prohibiting unions from acting in bad faith or with discriminatory or retaliatory motive.

Collectively, this pattern of retaliatory terminations, refusal to process or properly pursue grievances, selective enforcement of rules, and failure to investigate member complaints constitutes systemic violations of the Duty of Fair Representation, denial of due process, and abuse of authority. These actions have chilled protected activity, eroded member trust, and exposed the organization to substantial legal and regulatory liability. Immediate independent investigation, remedial action, and accountability are required to restore lawful representation and protect members’ rights.

Under the LMRDA, union officers are obligated to act in the best interests of the organization and its members. Additionally, under the TCU Constitution and Bylaws, officers are required to faithfully perform their duties, avoid conduct detrimental to the organization, and uphold the rights and interests of the membership. We assert that these obligations have not been met.

Katrina Coleman engaged in deliberate, direct, and improper interference in local elections. Her conduct exceeded any permissible role of oversight and constituted a sustained pattern of bad-faith involvement intended to influence outcomes, discredit duly appointed board members, and fabricate a false narrative of election misconduct in the absence of substantiated evidence. This conduct violated core principles of democratic governance and undermined the integrity of the election process.

Ms. Coleman’s actions and omissions constitute violations of fundamental union constitutional requirements guaranteeing fair elections, impartial administration, and equal member participation. By promoting false allegations of election impropriety and targeting board members who lawfully executed their duties, she denied affected members procedural due process, including the right to a fair and unbiased review of accusations, notice of specific charges, and an opportunity to respond.

There are grave and well-founded concerns regarding Ms. Coleman’s coordinated alignment with individuals later determined to be ineligible participants in the elections. These individuals acted in concert to harass, intimidate, and bully members involved in administering and overseeing the elections. Ms. Coleman’s failure to intervene, coupled with her apparent endorsement, protection, and facilitation of this misconduct, represents a breach of fiduciary duty owed to the membership, including the duties of loyalty, good faith, and impartial representation.

Following her promotion to National Vice President, Ms. Coleman leveraged her authority to persuade national-level executives that the elections were tainted by fraud or foul play. Acting on these unsubstantiated allegations, the National Office ordered the elections to be rerun without any investigation, evidentiary findings, or due-process review. This action violated established constitutional election procedures, ignored principles of fundamental fairness, and deprived members of their legally protected right to have their votes counted and respected.

This conduct further constitutes election interference and retaliatory conduct, as it punished board members and participants for carrying out their lawful responsibilities, chilled member participation, and deterred future involvement through fear of reprisal. The rerun of the election without investigation reflects arbitrary and capricious decision-making and exposes the organization to significant legal and regulatory risk.

Collectively, this pattern of conduct represents an abuse of authority, a breach of fiduciary and constitutional obligations, a denial of due process, and a violation of members’ democratic rights. The resulting harm includes the erosion of institutional credibility, the invalidation of member votes, and the creation of a hostile and retaliatory environment. This matter warrants immediate independent investigation, remedial action, and accountability, including review of the election rerun, restoration of member voting rights, and appropriate disciplinary measures.

Accordingly, we formally demand the following:

1. Immediate initiation of formal internal charges pursuant to the TCU National Constitution.

2. A transparent investigation conducted by an impartial body.

3. A membership hearing consistent with due process protections.

4. A vote on removal in accordance with constitutional procedures.

This petition is submitted in order to protect the integrity of TCU National and to restore confidence among the membership.

We reserve all rights afforded under federal labor law and the TCU Constitution.

Respectfully submitted,

Concerned Members of TCU