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Union officials are entitled to engage in robust debate which can include
strong language directed against management officials. This may include
discussions that are uninhibited, robust, wide-open and sometimes uncivil.
It may include language that might be considered intemperate, abusive and
An employee, who is also a union officer, interrupts an office birthday celebration to declare the event a "blatant and ridiculous display of management's power." The union officer later complains about the dress code, calling a district manager "ridiculous," and speaking loudly about her supervisor. (This is not robust debate because the employee/union officer is not acting in the capacity of a union representative nor did it occur within a discussion between the agency and the union regarding working conditions.)