Payne, 19 OCB2d 4 (BCB 2026)
Petitioner claimed that the Union breached its duty of fair representation in violation of NYCCBL ยง 12-306(b)(3) by failing to adequately represent her in seeking a reasonable accommodation and discriminating against her on the basis of her disability. The Union argued that it did not breach its duty of fair representation because there is no contractual right to a reasonable accommodation and it did not agree to represent her in her efforts to obtain an accommodation. The Board found that Petitioner failed to establish that the Union violated the NYCCBL. Accordingly, the petition was dismissed.