The following excerpt is from Golden v. Local 55 of Intern. Ass'n of Firefighters, 633 F.2d 817 (9th Cir. 1980):
Plaintiffs' claim regarding discrimination in promotion focuses on two events. First, plaintiffs object to the union's retention of counsel in Palmer v. City of Oakland, supra. Whether this point is treated as a disparate treatment or impact claim, the court had sufficient evidence to reject it.
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