Williams v. UNITED AUTO WORKERS LOCAL 501
George A. Williams, laid off by Bell Aerospace Wheatfield in October 1992, initiated a "hybrid" action under § 301 of the LMRA. He alleged breaches of the collective bargaining agreement by Bell, a breach of the duty of fair representation by Local 501, its officials, and the International Union, and a conspiracy claim. Defendants moved for dismissal and summary judgment, arguing Williams failed to exhaust internal union remedies. The court denied the defendants' motion, finding that Williams' failure to exhaust internal union remedies was excused due to the uncertainty of available remedies and the union's lack of guidance. The court deferred rulings on other issues.