The following excerpt is from Greene v. St. Barnabas Hosp., 1199seiu United Healthcare Workers E., 17-1089-cv (2nd Cir. 2018):
Additionally, the district court properly concluded that the Union did not act in bad faith. "A union acts in bad faith when it acts with an improper intent, purpose, or motive." Spellacy, 156 F.3d at 126. Bad faith acts include "fraud, dishonesty, and other intentionally misleading conduct." Id. Tactical decisions and mere negligence do not amount to bad faith. Barr v.
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