Decision 0451S – California State Employees Association (Norgard)
Decision Date: December 7, 1984
Decision Type: PERB Decision
Perc Vol: 9
Perc Index: 16018
800.04000 – Scope of Duty; Internal Union Affairs
Duty of fair representation applies to union's internal affairs only on a showing that the internal activity would have a substantial impact on employees' relationship with their employer. Allegation of DFR violation because of affiliation of an independent union with an international AFL-CIO union is insufficient to state prima facie case.