Mealey's (December 8, 2022, 7:41 AM EST) -- NEW YORK — A parochial school teacher failed to successfully bring a duty of fair representation claim against the union representing him under the guidance in NLRB v. Catholic Bishop of Chicago, but dismissal was due to failure to state a claim rather than lack of federal subject matter jurisdiction as the trial court held, a Second Circuit U.S. Court of Appeals panel ruled in a matter it noted was one of first impression....