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The Supreme Court held 11/3/1999 that a union does not breach its duty of fair representation by negotiating a union security clause that tracks the language of section 8(a)(3) of the National Labor Relations Act (NLRA) without explaining in the agreement the Supreme Court's interpretations of section 8(a)(3). The petitioner had complained that a union security clause in a collective bargaining agreement negotiated by the Screen Actors Guild (SAG) should have explained that the Court's decisions in NLRB v. General Motors Corp., 373 U.S. 734 (1963), and Communications Workers v. Beck, 487 U.S. 735 (1988), permit "unions and employers to require only that employees pay the fees and dues necessary to support the union's activities as the employees' bargaining representative." The Court held that the SAG's conduct was neither arbitrary nor in bad faith since the language of section 8(a)(3) contains "terms of art" that "encompass the rights that we announced in General Motors and Beck." It opined that requiring unions to spell out all of the "intricate rights and duties associated with a legal term of art" in these clauses would convert contracts into "massive and unwieldy treatises" with "no discernible benefit." Justices Kennedy and Thomas concurred to express their view that the Court's opinion does not immunize agreements where the section 8(a)(3) shorthand is inserted with the intent or effect of deceiving employees.