To show “bad faith,” plaintiff must show the union acted with “an improper intent, purpose, or motive.” Spellacy v. Airline Pilots Ass’n-Int’l, 156 F.3d 120, 126 (2d Cir.1998). Bad faith “encompasses fraud, dishonesty, and other intentionally misleading conduct.” Id. Plaintiffs must also show that the union’s actions caused them injury. Wood v. Int’l Bhd. of Teamsters, Chauffeurs, Warehousemen & Helpers, Local 406, 807 F.2d 493, 502 (6th Cir.1986) (“‘[C]ourts have held unions not hable for breaches of their duty of fair representation absent evidence that but for the union’s conduct, the employee would not have been injured.’ ” (quoting Anderson v. United Paperworkers Int’l Union, 641 F.2d 574, 580 n. 8 (8th Cir.1981))); see also Williams v. Molpus, 171 F.3d 360, 364 (6th Cir.1999) (<HOLDING>); Black, supra, 15 F.3d at 585 (same). A union
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 where an employee has never requested the union to file a grievance the employee can hardly argue a breach of the duty of fair representation on the unions part holding that a jail inmate does not have a constitutional entitlement to an adequate grievance procedure and the ineffectiveness or even absence of a grievance procedure does not give rise to a constitutional claim holding that in the grievance representation context an employee must prove that the unions acts tainted the grievance procedure such that the outcome was more than likely affected by the unions breach internal citation and quotation omitted holding that an ineffective grievance procedure bars employers defense based on that procedure