Does a party have to exhaust intra-union remedies under 29 U.S.C. 411(a)(4) before filing a lawsuit?

MultiRegion, United States of America

The following excerpt is from Kofoed v. Int'l Brotherhood of Elec. Workers, 237 F.3d 1001 (9th Cir. 2000):

The decision to require a party to exhaust intra-union remedies under 29 U.S.C. 411(a)(4) before filing suit is reviewed for an abuse of discretion. See Stelling v. IBEW, Local Union No. 1547, 587 F.2d 1379, 1391 (9th Cir. 1978).

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