Decision 0889E – Los Rios College Federation of Teachers, California Federation of Teachers/American Federation of Teachers (Violett)

In order to state a prima facie violation of the duty of fair representation, a charging party must show that the union's conduct was arbitrary, discriminatory, or in bad faith. Arbitrary conduct requires a showing of conduct that was without rational basis or was devoid of honest judgment; p. 8.

Exclusive representative not obligated to bargain a particular item benefiting certain unit members.

In duty of fair representation cases, the six month limitation period runs from the date the charging party knew or reasonably should have known that further assistance from the union was unlikely; p. 7.

Consolidation of 11 separate charges on appeal are appropriate where the unfair practice charges are identical and the charging parties are similarly situated; p. 4.