Karahalios v. National Federation of Federal Employees, Local 1263

Karahalios (plaintiff) was a non-union employee of the Defense Language Institute/Foreign Language Center, Presidio of Monterey. Karahalios was given a promotion, but then demoted after another employee, Kuntelos, filed a grievance against him. Kuntelos was then promoted to Karahalios’ position. The National Federation of Federal Employees, Local 1263 (union) (defendant) represented Kuntelos in his grievance and promotion. Karahalios then filed a grievance regarding his demotion. The union declined to represent Karahalios in his grievance citing a conflict of interest due to its representation of Kuntelos. Karahalios then filed an unfair labor practices charge with the Federal Labor Relations Authority (FLRA) against the Institute and the union. Under Title VII of the Civil Service Reform Act (CSRA), unfair labor practice complaints are heard by the FLRA. The FLRA is authorized to order remedial action, such as awarding backpay. The General Counsel of the FLRA ruled that the union had violated its duty of fair representation and filed a complaint against the union. The complaint was resolved without any personal benefits to Karahalios, and as a result, Karahalios filed an action for damages in the federal district court against the institute and the union. The district court ruled that Karahalios could bring a private right of action against the union. The court of appeals reversed. Karahalios appealed and the Supreme Court granted certiorari.