It cannot be stressed enough that every single contract violation causes harm to a letter carrier. Find that harm and talk about it. Every grievance should have this in it. When a grievance leaves your desk, you are relying on someone outside of the NALC to agree with you. That may be your own front line supervisor, a Step B team, or an arbitrator.
In contract grievances, the NALC carries the burden of proof. For that reason, in many contract grievance templates you will see a section on shifting the burden of proof moving forward to the Postal Service. Two arbitration decisions by Arbitrator Carleton Snow lay out this argument for us. Those decisions and the argument to apply them can be found under the Start Time template, for those who would like to review. There are exceptions, of course. For instance, if management posts a holiday schedule after the deadline and admits this, but only disputes the remedy . . . there is no need to argue burden of proof. Of course you still need to provide your evidence, but the emphasis should be on reaching the proper remedy. That is often the case with overtime issues as well - the hours speak for themselves, it is often the remedy that is the focus of your argument.
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You will find (hopefully) that the template contentions on this site follow a similar pattern. The violation or discipline charge is described first. Next, any procedural arguments are offered. It is important to emphasize in your grievance that fatal procedural errors are the grounds for deciding in favor of the NALC without consideration of the merits. Then your focus should move onto how the contract was violated. Finally, make sure you reiterate your requested remedy and explain why it resolves the grievance.
In discipline cases, have a copy of the just cause principles from chapter 16 of the JCAM in front of you and go through each aspect of the just cause principle. Since disciplinary actions can have so many variables, most of the discipline grievance templates will be targeted for violations of specific just cause principles. For instance, there may be a grievance example for arguing improper concurrence and another for failure to conduct a proper investigation. You may need to use both of these examples in one grievance if both deficiencies are present in the issued discipline.
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Every disciplinary letter will have the charges, and the alleged contract violations. Look at each carefully, postal management tends to think that more is better when it comes to discipline and that throwing the book at a letter carrier ensures success. Often times you will find charges that don't apply. As example, if the carrier is being charged with calling in sick too often and one of the charges in the discipline is abandoning the mail or failure to be diligent and efficient . . . these have nothing to do with being regular in attendance. If you take a look in the toy box, you will find some good resources.
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Another thing management likes to do is to escalate levels of discipline for dissimilar offenses. For instance, giving a letter carrier a letter of warning for attendance issues and then a 7-day suspension for a vehicle accident would not be considered corrective. Without even looking at the merits, there is no evidence that a letter of warning would not correct a safety deficiency in operating a postal vehicle. We should always argue that corrective discipline means starting at the lowest possible level for each specific issue. Several regional arbitrators have supported this position and some sample decisions are provided in the toy box under "Tracks of Discipline".
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Please remember that most arbitration decisions cited or attached as exhibits here are regional decisions, and not national decisions. This means that they are not the final word but can only be provided for persuasive value. It is a good idea to include in your arguments that you are providing regional arbitration decisions to show a Step B team or an arbitrator how other respected members of their community have ruled on the same issue in the past. This is more effective than telling an arbitrator that he must rule the same way as someone else has.