In the case of Chauffeurs, Teamsters and Helpers Local No. 391 v. Terry et al., the U.S. Supreme Court held that a union member could sue his or her union for breaching its duty of fair representation under federal labor law in arbitration proceedings, and that such claims were not limited to cases where the underlying dispute was based on an employer's alleged violation of a collective bargaining agreement (CBA). The plaintiffs were truck drivers who had been laid off by their employer due to lack of work but claimed they should have been transferred to other positions within the company according to seniority rules in their CBA. They argued that their union failed them by inadequately representing them during grievance procedures with their employer about this issue. The court ruled in favor of these employees, stating unions can be sued for damages if they do not fairly represent all members during disputes over contract interpretation or administration.

In the dissenting opinion for CHAUFFEURS, TEAMSTERS AND HELPERS LOCAL NO. 391 v. TERRY et al., Justice Blackmun argued that the majority's decision to allow a jury trial under Section 301 of the Labor Management Relations Act was incorrect and inconsistent with previous case law. He contended that this ruling would disrupt labor relations by introducing uncertainty into dispute resolution processes traditionally handled through arbitration or administrative proceedings. Furthermore, he expressed concern about potential bias from juries unfamiliar with complex labor issues and warned against undermining federal labor policy favoring collective bargaining and private dispute resolution mechanisms in union contracts.