## Facts

- Paul Karahalios, a federal employee and nonunion member, worked in a bargaining unit for which NFFE Local 1263 was the exclusive representative.
- Karahalios was promoted into a reopened “course developer” position at the Defense Language Institute.
- The union arbitrated on behalf of another employee (a union official) and obtained an award that led the agency to reassign the position to that employee, demote Karahalios, and deny his internal protest.
- Karahalios requested that the union pursue a grievance for him; the union declined, citing a conflict with its prior advocacy.
- Karahalios filed unfair labor practice charges with the Federal Labor Relations Authority (FLRA), alleging the union breached its statutory duty of fair representation under the Civil Service Reform Act of 1978 (CSRA).
- The FLRA General Counsel proceeded on the charge, but the matter ended in a settlement requiring the union to post a notice promising representation; Karahalios argued the settlement gave him no individual relief.
- After the General Counsel rejected that objection, Karahalios filed a federal district court action seeking damages for breach of the duty of fair representation.

## Issues

1. Whether Title VII of the CSRA creates an express or implied private cause of action in federal district court against a federal-sector union for breach of the statutory duty of fair representation.
2. Whether the CSRA’s designation of such a breach as an unfair labor practice commits enforcement exclusively to the FLRA and its General Counsel.

## Decision

- The Supreme Court affirmed the Ninth Circuit.
- Title VII does not expressly create a private right of action for breach of the duty of fair representation.
- No private right of action may be implied because Congress provided a specific administrative enforcement scheme through the FLRA and limited judicial review mechanisms that do not include a district court damages action.
- Enforcement authority over the duty of fair representation under the CSRA rests with the FLRA and its General Counsel.

## Legal Principles

- A federal-sector union’s duty of fair representation under CSRA Title VII is enforceable as an unfair labor practice through FLRA processes initiated by the FLRA General Counsel.
- When Congress creates a comprehensive remedial and review structure, courts generally will not imply additional judicial remedies absent clear statutory indication.
- The limited judicial review provisions in the CSRA support the conclusion that Congress did not authorize parallel district court suits for duty-of-fair-representation breaches.

## Conclusion

The Court held that CSRA Title VII provides no private federal court cause of action for damages based on a federal-sector union’s breach of the statutory duty of fair representation; the statutory enforcement route is through FLRA unfair labor practice proceedings and the review avenues specified by the CSRA.


Karahalios v. Nat'l Fed'n of Fed. Emps., Local 1263, 489 U.S. 527 (1989)