Issues: (1) Whether Section 302(e) of the Labor Management Relations Act, 29 U.S.C. § 186(e), provides for a private right of action; and (2) whether a labor organization violates its duty of fair representation by refusing to honor, at the end of the next applicable irrevocability period, employees’ check-off authorization revocations that are not sent during an annual, fifteen-day window period and by certified mail.
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