the grievance arbitration procedures provided for under the collective bargaining agreement before suing the employer for breach of contract. However employees do not usually have to exhaust such procedures if they are suing only the union, since very few collective bargaining agreements even allow for the filing of a grievance against the union by covered employees. To the extent that an employee might have a breach of contract claim against a union arising out of its performance of its duty to represent that employee, the courts will apply the same deferential standards and procedural requirements that they would employ if the worker sued the union on a breach of the duty of fair representation theory. See also Unfair labor practice References United States business law Labor relations