REINHARDT, Circuit Judge:
When Jeanne Herman, a member of an office-worker's union, was abruptly terminated after 36 years of service, she brought suit against her employer, a local of the Carpenter's union, asserting a variety of claims. This appeal from a grant of summary judgment in favor of Herman's employer raises several questions: 1) Under what circumstances may a union member bring a breach of contract claim directly against her employer without exhausting...
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