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

Single Topic for Decision 2087E

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Charge failed to establish that union violated its duty of fair representation by failing to provide members sufficient time to comment prior to holding a tentative agreement ratification election. Charge failed to demonstrate that the attempted refusal to permit one individual to speak at two informational meetings had a substantial impact on employment relationship with the District so as to violate the duty of fair representation, where employees were provided ample notice of the proposed contracts prior to the ratification vote and charging parties were not prevented from expressing their views by other means. Charge also failed to establish that union’s alleged failure to adhere to its internal rules had a substantial impact on charging parties’ employment relationship, or that any decisions were made without a rational basis or devoid of honest reason.