The Supreme Court of the United States has held that a union may be liable to a discharged employee for a portion of his lost wages when the union breaches its duty of fair representation.
Bowen v. United States Postal Service, 103 S. Ct. 588 (1983).
George E. Kunst Jr.,
Labor Law - Union's Duty of Fair Representation - Apportionment of Damages Between an Employer and a Union in a Hybrid Section 301 Suit,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol22/iss4/9