In the 1990 case of International Organization of Masters, Mates & Pilots v. Timothy A. Brown, the U.S Supreme Court ruled in favor of a union member who had been expelled from his union for crossing a picket line during a strike and subsequently sued to recover lost wages and benefits. The court held that under federal labor law, specifically Section 301(a) of the Labor Management Relations Act (LMRA), an individual has the right to sue their own union for damages resulting from wrongful expulsion or suspension if it is proven that such actions were taken without fair procedures being followed by the Union's governing body. This ruling reinforced individuals' rights within unions and established important precedents regarding internal disciplinary procedures.

In the dissenting opinion for International Organization of Masters, Mates & Pilots v. Timothy A. Brown, Justice Blackmun argued that the majority's decision was inconsistent with previous rulings and federal labor law principles. He contended that a union should not be held liable for breaching its duty of fair representation simply because it failed to inform an employee about a job opportunity when there is no evidence showing discriminatory or bad faith conduct by the union. The justice believed this ruling could potentially burden unions with excessive responsibilities and liabilities beyond what is reasonable or necessary under existing laws governing labor relations in America.