Union’s Breach of DFR Must Cause Employee's Failure to Exhaust CBA Remedies: Fourth Circuit | Practical Law
In Groves v. Communication Workers of America, the US Court of Appeals for the Fourth Circuit held that a hybrid claim under Section 301 of the Labor Management Relations Act (LMRA) requires a causal connection between the union's breach of its duty of fair representation (DFR) and the employee's failure to exhaust a collective bargaining agreement's (CBA) contractual remedies.