Staudner v. Robinson Aviation, Inc., No. 17-1928 (4th Cir. 2018)Annotate this Case
The judicially mandated exhaustion requirement is a nonjurisdictional precondition to suit under section 301(a) of the Labor Management Relations Act. Plaintiff filed suit against his union and former employer under section 301 for breach of a collective bargaining agreement that governed his employment. The Fourth Circuit reversed the district court's dismissal of the action based on failure to exhaust the agreement's grievance procedures. The court held that the district court erred in treating exhaustion as a matter of jurisdiction. The court also held that the district court erred in holding that the collective bargaining agreement in fact required exhaustion.