UNION UNFAIR PRACTICES; DUTY OF FAIR REPRESENTATION – In General; Prima Facie Case

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To constitute an unfair practice, separate from DFR, union conduct must tend to or actually result in some harm to EERA guaranteed rights. See Carlsbad #89; sections 3540 and 3543 do not give employees more rights in the internal activities of an employee organization than they have under section 3544.9; p. 13.