UNION UNFAIR PRACTICES; DUTY OF FAIR REPRESENTATION – Negotiations

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The Association is not required or expected to satisfy all members of the bargaining unit it represents, and the duty of fair representation does not mean that the Association is barred from making contracts which may have unfavorable effects on some of the members. A wide range of reasonableness must be allowed a statutory bargaining representative in serving the unit it represents. Association failed to contact all employees affected by a potential contract change for a meeting to discuss the change. However, it sought to correct the problem by getting an accurate list from the District. Association's failure to gain the benefit for some employees, provide requested minutes and answer several questions do not demonstrate retaliation, or a DFR.