Decision 0400E – California School Employees Association-Chapter 507 (Spiegelman)

The period of limitations begins to run at the point when an injury to the charging party becomes fixed and reasonably certain. In a duty of fair representation proceeding, the period began to run when the employee knew that he was dissatisfied with the union's representation. The period does not date from the employee's receipt of a vague response from the union to his complaint about representation.

No equitable tolling where charging party efforts to resolve his case did not rise to status of alternative legal remedies; p. 3, dismissal letter.