What is the current state of the law on "some evidence" in union proceedings in which an officer is expelled for indefinite period?

There is high authority holding that union proceedings in which an officer is expelled for an indefinite period need only be supported by "some evidence." (Boilermakers v. Hardeman, 401 U.S. 233, 245-246, 91 S.Ct. 609, 616-617, 28 L.Ed.2d 609.)

California's high court holds that judicial determinations whether an asserted claim is of a "fundamental vested right" must be made on a "case-by-case" analysis. (Merrill v. Department of Motor Vehicles, 71 Cal.2d 907, 915, 80 Cal.Rptr. 89, 458 P.2d 33.)