Case: Labor Relations/Fair Representation (6th Cir.)

The Sixth Circuit affirmed a district court’s grant of summary judgment to General Electric and the Communications Workers of America on the hybrid section 301 claim of a machine operator alleging unfair representation by the CWA in his challenges to GE’s decisions not to promote him to toolmaker. Issue preclusion bars his claim because the NLRB adjudicated his unfair representation charge and dismissed it, and he received a full and fair opportunity to litigate his case before the board.