(July 7, 2016, 11:30 AM EDT) -- PASADENA, Calif. — A worker bringing a prima facie claim of disability bias against a union does not need to show a breach of the duty of fair representation, a Ninth Circuit U.S. Court of Appeals panel ruled July 5 (Rosemary Garity v. APWU National Labor Organization, No. 13-15195, 9th Cir.; 2016 U.S. App. LEXIS 12395)....