The Federal Service Labor-Management Relations Statute sets forth union guidelines for collective bargaining representation in the federal sector. A labor organization with recognized exclusivity is responsible for the non-discriminatory representation of all bargaining unit employees without regard to union membership. In National Treasury Employees Union v. Federal Labor Relations Authority, a case of first impression, the court considered whether a federal employees union may, in accordance with statutory obligations, consider union membership in determining the type of representation it provides to individual employees. The court held that by denying non-union members attorney representation and substituting representation by a shop steward or chapter official, the National Treasury Employees Union (NTEU) committed an unfair labor practice and violated the duty of fair representation. This Article discusses the above case.
18 Suffolk U.L. Rev. 845 (1984)