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4640 An employee of a union breached fiduciary duties while so employed by secretly working to have the union decertified as a bargaining agent; in an action by the employer, a damages award consisting of salary and benefits paid to the unfaithful employee during the period of breach was appropriate; since the employee could have worked to decertify the union after resigning, the union’s expenses in campaigning against decertification were not shown to be proximately caused by the breach of fiduciary duty.CitationSERVICE EMPLOYEES v COLCORD (Unfaithful Employee) 160 CA4 362 [See: Williams v Wraxall 33 CA4 120, T/AT 4/95]
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