American Federation of Government Employees, Local 2343 v. Federal Labor Relations Authority

TATEL, Circuit Judge:

After a government employer refused to provide documents requested by a union in connection with a pending grievance, the Federal Labor Relations Authority dismissed the union’s unfair labor practice complaint, finding that the union failed to articulate “particularized heed” for the documents. Because the Authority reasonably applied the appropriate legal standard, we deny the union’s petition for review.

I

Collective bargaining and labor relations in the federal government are governed by the Federal Service Labor-Management Relations Statute, Pub.L. No. 95-454, § 701, 92…