Poe v. Hawai'i Labor Relations Board

Opinion of the Court by

ACOBA, J.

We hold that under Hawai'i Revised Statutes (HRS) chapter 89, pertaining to collective bargaining in public employment, a public employee pursuing an individual grievance exhausts his or her administrative remedies when the employee completes every step available to the employee in the grievance process and a request to the employee’s exclusive bargaining representative to proceed to the last grievance step, which only the representative can undertake, would be futile. Accordingly, where, as here, the Ha-wai'i Government Employees Association (HGEA or Union),…