Karahalios v. National Federation of Federal Employees, Local 1263

Karahalios (plaintiff), a non-union federal employee, was promoted and then demoted after a coworker, Kuntelos, filed a grievance against him and was promoted into his position; the union representing Kuntelos, National Federation of Federal Employees, Local 1263 (defendant), declined to represent Karahalios in his own grievance over the demotion, citing a conflict of interest from having represented Kuntelos. Karahalios filed an unfair-labor-practice charge with the Federal Labor Relations Authority (FLRA), which agreed the union had breached its duty of fair representation and filed its own complaint against the union - but that FLRA proceeding resolved without any personal benefit to Karahalios. Karahalios then sued the union and his employing institute for damages directly in federal district court; the district court allowed a private right of action against the union, but the court of appeals reversed, and Karahalios sought Supreme Court review.