GENERAL LEGAL PRINCIPLES; WAIVER – In General

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Union waived its right to pursue future claims against the State employer for State’s failure to implement union leave provisions of its last, best, and final offer. Union entered into a written union leave agreement that contained a clause which explicitly waived the union’s right to pursue future claims on the subject. Because the plain language of the agreement constituted a clear and unmistakable waiver of all future claims, the Board did not consider the bargaining history of the agreement presented by the union.