Simo

This suit arises out of a contentious labor struggle at a garment factory in San Bernardino, California. Twenty-five garment workers (“the workers”) brought suit against their union and its officials after the union engaged in secondary pressure to remove work from their factory. The workers alleged that their own union retaliated against them because they sought to have it decertified, in breach of the duty of fair representation (“DFR”), and that the union and the individual defendants initiated a campaign of harassment and intimidation constituting intentional infliction of emotional distress (“IIED”). In an unpublished order entered on April 23, 2001, the district court granted summary judgment on all claims, concluding that the workers had not produced evidence demonstrating the bad faith necessary for a DFR claim, nor evidence of outrageous conduct necessary for an IIED claim. We affirm the district court’s ruling.

I. FACTUAL AND PROCEDURAL BACKGROUND

At all times relevant here, the Union of Needletrades, Industrial and Textile Employees Southwest District Council (“UNITE-SW”) was the exclusive bargaining agent of the workers of Sorrento Coats, Inc. (“Sorrento”). UNITE-SW…