A black 55-year-old Jehovah’s Witness working as a Clerk for the Monmouth County, N.J. Division of Social Services failed to state a claim of unfair representation against a New Jersey Area Director and a staff representative of the Communications Workers of America. She only stated that the two union officials didn’t represent her during disciplinary proceedings against her, and she didn’t discuss how they acted in bad faith or in an arbitrary manner when they failed to prosecute her grievances and failed to defend her in the disciplinary action. The case is Barnes v. Monmouth Cty. Div. of Soc. Servs., 2018 BL 458073, D.N.J., No. 3:18-cv-7752 (PGS)(TJB), 12/11/18
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