The AFSCME union representing security guards at the Museum of Natural History in New York City was not liable for violating the duty of fair representation when it decided not to seek arbitration on a member’s claim for accommodation of her disability, a federal District Court in New York has held. The guard was first injured in 2003 when a patron physically attacked her. She returned to work after more than a year of medical leave. In 2005, she was injured again, this time by a mechanical garage arm in the Museum’s parking lot, and took several months medical leave. In 2006, she had surgery on her arm related to her prior injuries and missed another eight months from work. When she...