& Motor Coach Employees v. Lockridge, 403 U.S. 274, 301, 91 S.Ct. 1909, 29 L.Ed.2d 473 (1 es not breach its duty of fair representation simply because it takes a position adverse to the interests of some members while benefiting others. Humphrey v. Moore, 375 U.S. 335, 349-50, 84 S.Ct. 363, 11 L.Ed.2d 370 (1964). Similarly, “[t]he mere fact that plaintiffs are in a minority group within their union organizations and that they were adversely affected by the actions or inactions does not establish that the union acted with hostile or discriminatory intent.” Ratkosky v. United Transp. Union, 843 F.2d 869, 878-79 (6th Cir.1988). Courts have upheld union actions which favor one represented group over another as non-arbitrary. See Jeffreys v. Commc’n Workers, 354 F.3d 270, 276 (4th Cir.2003) (<HOLDING>); Ryan v. Printing Pressmen’s Union, 590 F.2d
holding that union did not breach its duty of fair representation when it accepted a contract that provided severance pay for some active workers but not for laid off workers who were recalled holding that where employee cannot establish unions breach of duty of fair representation in failing to process grievance he must abide the outcome of the contractual remedies holding that the duty of good faith and fair dealing is a contractual duty holding that unions interpretation of a contractual provision necessarily favorfing some workers over others did not violate the duty of fair representation holding that a union may breach its duty of fair representation by rejecting an employees interpretation of the collective bargaining agreement if the unions interpretation is itself arbitrary or unreasonable