In what circumstances can a plaintiff bring a tort action against a union official?

MultiRegion, United States of America

The following excerpt is from Casumpang v. International Longshoremen's & Warehousemen's Union, 269 F.3d 1042 (9th Cir. 2001):

In Ross v. IBEW, 513 F.2d 840 (9th Cir. 1975), the plaintiff brought a tort action seeking recovery for damages allegedly inflicted against him by union officials during his campaign for a union position.

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