The Alberta Labour Relations Board granted summary dismissal in a duty of fair representation complaint finding that the actions of the Alberta Teachers’ Association were in its capacity as a professional regulator, not as a trade union, and therefore outside the jurisdiction of the Board: Mennes v The Alberta Teachers’ Association, 2025 ALRB 32

While dismissing a duty of fair representation complaint, the Alberta Labour Relations Board noted that the duty of fair representation does not apply to unions in collective bargaining. However, when the union negotiates a letter of understanding that alters the terms of a collective agreement, the union must ensure employees have an opportunity to provide input and a forum to express their wishes: Rietveld v Canadian Union of Public Employees, Local 30, 2025 ALRB 33