In what circumstances will a white member of a union be able to intervene in a race discrimination action?

Perhaps the closest case in point is our own Rios v. Enterprise Association Steamfitters Local Union No. 638, 520 F.2d 352 (2d Cir.1975). The court had ordered affirmative action for the entry of black members into union "A" Branch. White members of union "B" Branch sought to intervene to assert that the union's preferences for members of "A" Branch discriminated against the members of "B" Branch. The court upheld a denial of intervention as of right on the basis that the would-be intervenors' exclusion from the other branch was a claim unrelated to the primary action, which was based on the union's duty under Title VII not to discriminate against non-whites in the admission of

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