The following excerpt is from United Bhd. of Carpenters & Joiners of Am. v. M, No. 13-35095 (9th Cir. 2014):
In Retana, a discharged hotel maid sued on behalf of Spanish-speaking members of her union, alleging that her union's failure to provide, for example, a Spanish translation of the collective bargaining agreement violated the duty of fair representation. Id. at 1021, 1023. Although we declined in that case "to attempt a . . . precise delineation of the scope of the duty of fair representation," we noted a possible violation of the union's duty "to make an honest effort to serve the interests of all members of the bargaining unit." Id. at 1024-25 (internal quotation marks omitted). The union's alleged failure to take relatively easy and inexpensive steps to accommodate its Spanish-speaking members suggested adequately under the relaxed pleading standard of Conley v. Gibson, 355 U.S. 41 (1957)that the union was not negotiating or administrating in good faith on their behalf.
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