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

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Unions owe a duty of fair representation to their members, and this requires them to refrain from representing their members arbitrarily, discriminatorily, or in bad faith. The duty of fair representation, however, is generally not breached by mere negligence. Rather, absent a showing of arbitrary exercise of power, a union is accorded wide latitude in the representation of its members.