KARAHALIOS V. NATIONAL FEDERATION OF FEDERAL EMPLOYEES, LOCAL 1263 489 U.S. 527 (1989) CASE BRIEF

KARAHALIOS V. NATIONAL FEDERATION OF FEDERAL EMPLOYEES, LOCAL 1263

489 U.S. 527 (1989)

NATURE OF THE CASE: This was a dispute over whether Title VII of the Civil Service Reform Act of 1978 confers a private cause of action against a breach of a union representing federal employees of its statutory duty of fair representation.

FACTS: Karahalios (P) was a Greek language instructor for the Defense Language Institute. P was not a union member but was within a bargaining unit of professional employees for which the National Federation of Employees Local 1263 was the exclusive bargaining agent. P applied for a course developer position. P won the position because the prior instructor, Kuntelos, who had held that position before it was abolished, declined to seek the reopened job through the competitive process. Kuntelos disputed the appointment of P as he claimed that he should have been given the position without the competitive application process. The Union agreed to arbitrate on behalf of Kuntelos and got him the opportunity to take the exam for which Kuntelos was given much more time and scored such that P lost the job. The Institute denied P's direct protest against what happened and the Union refused to prosecute his grievances because of the perceived conflict of interest. P filed unfair labor practice charges with FLRA, for the Institute violating its collective bargaining agreement and that the Union breached its duty of fair representation. The second charge was upheld and the General Counsel ordered that a complaint be issued against the Union. The Union and the FLRA entered a settlement whereby the Union posted notice-guaranteeing representation to all employees seeking a single position. P's contention on appeal was that this settlement provided him with no relief. P then filed for damages in district court. The court held that section 1331 supports jurisdiction. The court found that the Union breached its duty and awarded P attorney fees only. The Court of Appeals reversed; the CSRA precludes implication of a parallel right to sue in federal courts. The Supreme Court granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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