In the United States Supreme Court case of United Parcel Service, Inc. v. Mitchell et al., 1980, the court had to decide whether a state statute of limitations for personal injury claims could be applied to actions brought under Section 301 of the Labor Management Relations Act (LMRA). The plaintiff was an employee who filed suit against his employer and union alleging that they violated their duty of fair representation in handling his grievance over wrongful termination. The lower courts dismissed his claim based on New York's three-month limitation period for challenging arbitration awards. However, upon reaching the Supreme Court, it held that federal law governs timeliness for such suits and not state laws; therefore reversing and remanding the decision back to lower courts with instructions to apply a six-year statute of limitations borrowed from analogous provisions within LMRA itself rather than applying New York’s shorter time limit.

In the dissenting opinion for United Parcel Service, Inc. v. Mitchell et al., Justice Brennan argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism by allowing a state statute to dictate when a federal cause of action accrues. He contended that it was inappropriate to apply New York’s borrowing statute in this case because it would undermine Congress' intent in enacting Section 301 of the Labor Management Relations Act (LMRA). The LMRA intended to provide uniformity across states regarding labor disputes, but applying different state laws would lead to inconsistencies and unpredictability. Furthermore, he expressed concern about how this ruling could potentially limit workers’ rights by shortening their time frame for filing claims under collective bargaining agreements due to varying statutes of limitations among states.