In Service Employees Int'l. Union, Local 250 v. Colcord, a California court of appeal ruled that a California union representative who secretly created a new labor union while he was employed by Service Employees International Union Local 250 must return the salary he received during the period of his disloyalty. The court held that Colcord violated a fiduciary duty by making plans to create a competing union. Knowing a union contract was about to expire, the court found that Colcord and two other union representatives intentionally stalled negotiations and secretly made extensive preparations for the new union while employed by Local 250, including meeting with legal counsel and drafting a decertification petition, constitution and other documents. Shortly after resigning from Local 250, Colcord announced his competing union, began campaigning against Local 250 for the vote of covered employees and won the coveted collective bargaining election.