Midori Hosokawa v. Screen Actors Guild-American, Federation of Television & Radio
Plaintiff Midori Hosokawa, proceeding pro se, filed a lawsuit against Screen Actors Guild-American Federation of Television and Radio Artists (SAG-AFTRA) and its New York Local. She alleged breaches of SAG-AFTRA's duty of fair representation and its constitution, stemming from the Union's refusal to pursue her "upgrade" claims for compensation as a principal performer in a Verizon Droid commercial. SAG-AFTRA repeatedly informed Hosokawa that her claims were closed and warned her about persistent contact. Hosokawa's prior unfair labor practice charges with the NLRB were dismissed. The District Court granted SAG-AFTRA's motion to dismiss, ruling that the duty of fair representation claims were time-barred by the six-month statute of limitations, and the breach of constitution claims were either time-barred or lacked evidence of an actual breach.