UNION UNFAIR PRACTICES; DUTY OF FAIR REPRESENTATION – Other

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In Lane v. I.U.O.E. Stationary Engineers (1989) 212 Cal.App.3d 164 [260 Cal.Rptr. 634], the court applied a standard of care "akin" to a duty of fair representation only after the union had affirmatively undertaken representation in a forum where representation by the union was not mandatory. Because the union in this case did not undertake the charging party's representation before the SPB, a Lane standard of case is inapplicable; pp. 10-11.