The following excerpt is from Gardner v. International Telegraph Employees Local No. 9, 850 F.2d 518 (9th Cir. 1987):
Only one circuit has specifically addressed the limitations period for claims under section 104 of LMRDA. In Linder v. Berge, 739 F.2d 686 (1st Cir.1984), as in this case, the plaintiff's suit combined fair representation and section 104 claims. The court held the LMRDA claim "should be governed by the same statute of limitations as governs the unfair representation claim." Id. at 690.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.