UNION UNFAIR PRACTICES; DUTY OF FAIR REPRESENTATION – Scope of Duty; Internal Union Affairs

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Under the MMBA, a local union member employee may only challenge the parent union's failure to afford its members the opportunity to vote for or against a consolidation of local unions if the employee can demonstrate that such consolidation had a substantial impact on the employer-employee relationship. In this case, the employee has not alleged facts showing that her relationship with her employer was substantially affected by either SEIU's merger of her local union with other locals or SEIU's alleged failure to allow the employee’s bargaining unit to vote on the merger.