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Public employees are joining unions in increasing numbers. Even in the jurisdictions that prohibit public employees from striking, union membership may give employees benefits of more standardized and equitable grievance procedures. In such cases the collective bargaining agreement between union and management may make the union and the employees representative in a grievance procedure. But what happens if the union believes the termination was warranted and refuses to support the fired employee? Does the employee's membership in the union waive any rights to notice and hearing? See Winston and Cummings v. U.S. Postal Service, 585 F.2d 198 (7th Cir. 1978),

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