Full Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0445n.06 Case No. 26-1511 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Nov 04, 2026 ) KELLY L. STEPHENS, Clerk LORENZO WILLIAMS, ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE EASTERN DISTRICT OF FORD MOTOR COMPANY, et al., ) MICHIGAN Defendants-Appellees. ) ) OPINION Before: COLE, SUTTON, and THAPAR, Circuit Judges. THAPAR, Circuit Judge. In June 2019, Ford Motor Company fired Lorenzo Williams during his probationary period. United Autoworkers Union initially filed a grievance on Williams’s behalf. But in July 2021, the Union withdrew the grievance because it learned that Williams was let go because of job-performance issues. In January 2022, Williams filed a charge with the National Labor Relations Board alleging that the Union breached its duty of fair representation by failing to take his grievance to arbitration. The NLRB dismissed the charge in February 2022. At some later time (he doesn’t specify when), Williams tried to appeal the NLRB decision. But the NLRB refused to entertain the untimely appeal. In June 2025, Williams filed suit and brought a bevy of state and federal claims against Ford and the Union. The district court granted summary judgment to Ford on Williams’s No. 26-1511, Williams v. Ford Motor Co. Americans with Disabilities Act claims and dismissed his § 1981 claims. The district court also dismissed Williams’s intentional infliction of emotional distress claim and fair-representation claim under § 301 of the Labor Management Relations Act against the Union. Lastly, it declined to exercise supplemental jurisdiction over Williams’s state law claims against Ford. We affirm across the board. To start, Williams’s appellate brief leaves a lot to be desired. The brief contains only one page of argument. An appellant’s failure to raise an argument in his opening brief forfeits that issue on appeal. Island Creek Coal Co. v. Wilkerson, 910 F.3d 254, 255–56 (6th Cir. 2018). Construing the brief generously, Williams challenges only the district court’s holding that the statute of limitations barred his § 1981 counts against Ford and his § 301 claim against the Union. § 1981 Claims Against Ford. Williams alleges Ford discriminated against him because of his race and disability during his employment. Williams worked at Ford from March to June 2019. Since these claims have a four-year statute of limitations period, Williams had to file his claims no later than June 2023. Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369, 382–83 (2004) (citing 28 U.S.C. § 1658). But he didn’t file his complaint until June 2025, after the statute of limitations ran. Williams identifies no post-2019 conduct by Ford that would’ve extended his timeline to file suit. The complaint references a December 2023 interaction in which someone at Ford allegedly commented when Williams made a records request that Williams was “one of the Plaintiffs at 4763.” R. 13, Pg. ID 102. But the district court correctly found that this allegation wasn’t tied to Ford’s alleged discrimination during Williams’s employment, since it came several years after his employment and didn’t mention anything that happened during his employment period. -2- No. 26-1511, Williams v. Ford Motor Co. The comment also wasn’t an adverse employment action. An “employment action is adverse if it leaves the employee ‘worse off respecting employment terms or conditions,’” and a stray comment made four years after a plaintiff’s termination can’t have affected his employment. McNeal v. City of Blue Ash, 117 F.4th 887, 900 (6th Cir. 2024) (quoting Muldrow v. City of St. Louis, 601 U.S. 346, 355 (2024)). And because termination is a discrete act, the statute of limitations started running on the date of termination and wasn’t paused or restarted by a later comment. See Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101, 114 (2002). Williams does argue that he couldn’t have been aware of any final action by the defendants until the eventual refusal of his NLRB appeal. But any later NLRB appeal can’t save Williams’s claims against Ford. An NLRB appeal would’ve challenged the Union’s conduct, not Ford’s, so it can’t toll the statute of limitations for the discrimination claims against Ford. Since Williams’s § 1981 claims are time-barred, we affirm the district court’s dismissal of those claims. Unfair Representation under § 301 of the Labor Management Relations Act (LMRA). Like his § 1981 claims against Ford, Williams’s LMRA claims against the Union are untimely. These claims are subject to a six-month statute of limitations. DelCostello v. Int’l Bhd. of Teamsters, 462 U.S. 151, 169–70 (1983). That clock begins ticking on the day the employee knew or should’ve known of either the union’s or the employer’s final action, whichever occurred later. Robinson v. Cent. Brass Mfg. Co., 987 F.2d 1235, 1239 (6th Cir. 1993). The Union sent Williams a letter notifying him that it had withdrawn his grievance on July 30, 2021. Regardless of when he received that letter, Williams knew of the Union’s final action no later than January 25, 2022, when he filed an NLRB charge against the Union. So, even in the best-case scenario for Williams, the statute of limitations ran out in July 2022. He filed this suit in June 2025, so his claim is untimely. -3- No. 26-1511, Williams v. Ford Motor Co. And regardless, the statute of limitations wasn’t tolled by the NLRB charge Williams filed. Williams’s unfair representation claim “is wholly independent” of any charge before the NLRB. Adkins v. Int’l Union of Elec., Radio & Mach. Workers, AFL-CIO-CLC, 769 F.2d 330, 335 (6th Cir. 1985). So an NLRB filing doesn’t stop the clock on an unfair representation claim. And even if it did, that wouldn’t save Williams’s claim. The NLRB charge was dismissed in February 2022, so his claim would still be untimely based on a six-month statute of limitations running from that time. We affirm. -4-