Kravar v. Triangle Services, Inc., provides the most workable solution to date, balancing competing union, employer, and employee interests. Kravar gives an employee access to federal court, as a matter of right, in the face of union refusal to arbitrate his or her federal statutory claims.8 Although the Federal District Court for the Southern District of New York offered little discussion of the policy behind its new rule, there are sound policy rationales underlying it.



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