Karahalios v. National Federation of Federal Employees, Local 1263 case brief

Karahalios v. National Federation of Federal Employees, Local 1263 case brief summary
489 U.S. 527 (1989)

CASE SYNOPSIS

Petitioner teacher filed suit in district court, claiming that respondent union violated its fiduciary duties owed to teacher under Title VII of the Civil Service Reform Act of 1978 (CRSA), 5 U.S.C.S. § 7101. The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and determined that CRSA did not confer upon teacher a right to sue in federal court. Teacher appealed.

CASE FACTS
The teacher argued that federal employees had a private cause of action against a breach by a union representing federal employees of its statutory duty of fair representation. Union contended that under Title VII of the Civil Service Reform Act of 1978, 5 U.S.C.S. § 7101, no private cause of action existed.

DISCUSSION

• The court determined that the lower court was correct in determining that neither the language nor the structure of the Act showed any congressional intent to provide a private cause of action to enforce federal employee union's duty of fair representation. 
• Therefore, the court determined that teacher did not have a cause of action against union.

OUTCOME
The court affirmed the decision of the court of appeals.



Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)