Decision 1162E – California School Employees Association (Davison)
S-CO-361
Decision Date: June 26, 1996
Decision Type: PERB Decision
Description: Union violated its duty of fair representation by failing to adequately represent its African American membership.
Disposition: Dismissed for failure to state a prima facie case.
Perc Vol: 20
Perc Index: 27119
Decision Headnotes
800.04000 – Scope of Duty; Internal Union Affairs
The duty of fair representation does not extend to strictly internal union matters which do not substantially impact the relationship between the employee and the employer such as improper committee assignments and protocol; p. 2, warning letter.
801.01000 – In General
No violation where charge fails to state, with particularity, facts which indicate how or in what manner the exclusive representative's actions lack a rational basis or are devoid of honest judgment; p. 2, dismissal letter.