The U.S. Supreme Court case Karahalios v. National Federation of Federal Employees, Local 1263 in 1988 revolved around the issue of whether a union's breach of its duty to fairly represent all employees could be remedied under Section 301(a) of the Labor Management Relations Act (LMRA). The plaintiff, George Karahalios, was an employee who claimed that his union had unfairly represented him during disciplinary proceedings with his employer. He sought relief under Section 301(a), which allows for lawsuits against unions for breaches of contract. However, the court ruled in favor of the defendant - National Federation Of Federal Employees Local Union No.1263 - stating that federal sector labor-management relations are governed by statutes other than LMRA and hence section 301(a) does not apply here.

In the dissenting opinion for Karahalios v. National Federation of Federal Employees, Local 1263, Justice Blackmun argued that the majority's decision to allow a private cause of action under §301 was inconsistent with previous case law and Congressional intent. He pointed out that Congress had specifically chosen not to include a provision allowing individual members to sue their unions in the Civil Service Reform Act (CSRA). Instead, it established an administrative procedure for resolving such disputes through the Federal Labor Relations Authority (FLRA). By creating a new judicial remedy, he believed that the Court was overstepping its bounds and undermining this carefully crafted legislative scheme. Furthermore, he expressed concern about potential negative consequences of this ruling on labor relations within federal agencies. In his view, allowing individual lawsuits could disrupt collective bargaining processes and lead to increased conflict between union members and leadership.