EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – In General

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Argument that case was not ripe for review because employee did not request to withdraw from union membership until four months after expiration of contract is rejected. Continued union membership can only be required until 30 days prior to the expiration of the contract, and union was not free to refuse to honor requests to withdraw made after the expiration but prior to the effective date of a successor agreement.