Virginia Christiansen v. Apv Crepaco, Inc., and Blackhawk Lodge No. 957, International Association of MacHinists and Aerospace Workers

FLAUM, Circuit Judge.

A machine shop employee claimed that her employer was not paying her for skills she had obtained under a job training incentive program. Five years after first complaining to her union, the employee still had not received any skill-based pay increase and filed suit against the union for failure to represent her interests and against the company for breach of the collective bargaining agreement. The district court granted the defendants’ motion for summary judgment, holding that the employee’s claims were barred by the six month statute of limitations applicable to claims…