Kalyanaram v. Am. Ass'n. of Univ. Professors at The N.Y. Inst. of Tech., Inc., No. 12-3630 (2d Cir. 2014)Annotate this Case
Plaintiff filed suit against the Union alleging that it breached its duty of fair representation. The Union filed a motion for partial judgment on the pleadings, arguing that plaintiff's claim was time-barred. The court held that the statute of limitations on plaintiff's claim accrued when the arbitrator issued his final award even though the collective bargaining agreement provided that the arbitrator's decision shall be final and binding subject to appeal by either party. Further, a state court action to vacate the arbitration award did not toll that limitations period. Accordingly, the court affirmed the district court's grant of the Union's motion.