In Jeffreys v. Communication Workers of America, the Fourth Circuit in an opinion by Judge Wilkinson joined by Judge Traxler and District Judge Payne upheld the dismissal of the appellants' claims that their union failed to fulfill its duty of fair representation in connection with layoffs by their employer USAir.
Interestingly, William B. Poff of the Woods Rogers firm in Roanoke appeared for the 15 laid-off workers, so I would say they were more than fairly represented before the Court of Appeals.
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