Bartenders Union Local 165 operated an exclusive hiring hall from which it referred all bartenders employed by hotels belonging to the Nevada Resort Association. William Dickson, a bartender who wanted to be referred to employment through the union hall, asked the union business manager to allow him to look at the union's hiring records because he suspected another bartender had been improperly referred to a job ahead of him. The business manager refused to show the hiring records to Dickson or any other member of the union. The manager claimed that the records were confidential.

At Dickson's request, the General Counsel issued a complaint against Local 165 for violating Section 8(b)(1)(A) of the NLRA. The General Counsel believed that the denial of access to the records was tantamount to union denial of fair representation. The union, relying on Vaca v. Sipes, maintained that it had not acted in bad faith or in an arbitrary manner by preserving the confidentiality of its records.
Has the union breached its duty of fair representation toward Dickson? Decide. [Bartenders Local 165, 261 NLRB No. 67, 110 LRRM 1063]