In Prevas v. Hopkins, 905 F.Supp. 271 (D.Md. 1995), the plaintiff sued both his union and an investigation service, alleging they were negligent and had conspired to invade his privacy. 905 F.Supp. at 273.
The union-defendant filed a motion to dismiss for failure to exhaust internal union remedies. Id. at 274. The plaintiff argued that exhaustion would have been futile because he would not receive a fair hearing and the union procedures could not afford him a satisfactory remedy. Id. at 276.
The court granted the defendant's motion and dismissed the plaintiff's "speculative and unsupported" assertions. Id.