Illinois Appellate Court
Civil Court
Unions
Illinois Labor Relations Board certified AFSCME Union as exclusive representative of bargaiing unit composed of certain of Circuit Clerk's employees. Board's initial notification properly informed Circuit Clerk that it was required to include clear and convincing evidence with its response to petition. ALJ's order to show cause properly informed Clerk that it was required to include clear and convincing evidence in its supplemental submission to rectify weaknesses the ALJ identified in Clerk's response. Clerk failed to present clear and convincing evidence that Union used fraudulent or objectively coercive means to obtain majority support. (HUTCHINSON and BURKE, concurring.)