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Labor – No Need to Exhaust Internal Union Remedies.

November 26, 2013

The Maryland Court of Special Appeals held that a union member was not required to exhaust available internal union remedies before filing suit against the union and its president. In McClure et al v. Lovelace, a union member filed a defamation action against a local union and its president based on alleged disparaging statements made by the president. Among other things, the Court was asked to consider whether the union member’s claim was barred for failure to exhaust available internal Union remedies. The trial court had concluded that exhaustion was not required because the internal remedies did not provide for monetary damages as sought and were thus inadequate.