In DelCostello v. Teamsters, 462 U.S. 151 (1983), the Supreme Court was presented with the issue of what statute of limitations should apply to an employee's action against both his employer and his union. The court held that section 10(b)'s six-month period provided the closest analogy because such hybrid suits involve "those consensual processes that federal labor law is chiefly designed to promote--the formation of the collective agreement and the private settlement of disputes under it." Id. at 163 (quoting Auto Workers v. Hoosier Cardinal Corp., 383 U.S. 696, 702 (1966)). In DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151, 103 S.Ct. 2281, 76 L.Ed.2d 476 (1983), the Supreme Court held that the six-month statute of limitations period contained in section 10(b) of the National Labor Relations Act applies to "hybrid" suits where the employee alleges that the employer breached the collective bargaining agreement and that the union breached its duty of fair representation. Id. at 169-70. In DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151, 103 S.Ct. 2281, 76 L.Ed.2d 476 (1983), the Court maintained its view that a hybrid Sec. 301 of the Labor Management Relations Act action is not analogous to a contract claim, but retreated from the "imperfect" view that it was analogous to an action to vacate an arbitration award. The Court instead analogized hybrid Sec. 301 actions to unfair labor practice actions and therefore held applicable to hybrid Sec. 301 actions the six-month statute of limitations contained in Sec. 10(b) of the National Labor Relations Act. In DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151, 103 S.Ct. 2281, 2287-94, 76 L.Ed.2d 476 (1983), the Court refused to borrow an analogous state statute because federal policies were at stake and because federal law provided an even more analogous limitations period. Id., 103 S.Ct. at 2294. The Court reasoned that hybrid actions and actions under Sec. 10(b) of the National Labor Relations Act seeking relief from unfair labor practices require the assertion of similar rights and a similar balancing of interests. In both types of cases, "the proper balance between the national interests in stable bargaining relationships and finality of private settlements, and an employee's interest in setting aside what he views as an unjust settlement under the collective-bargaining system" is at issue. Id. (quoting United Parcel Service v. Mitchell, 451 U.S. 56, 70, 101 S.Ct. 1559, 1567, 67 L.Ed.2d 732 (1981)). In DelCostello v. Int'l Brotherhood of Teamsters, 462 U.S. 151, 103 S.Ct. 2281, 76 L.Ed.2d 476 (1983), the Supreme Court held that federal courts should "turn away from state law" and borrow a limitation period from elsewhere in federal law "when a rule from elsewhere in federal law clearly provides a closer analogy than available state statutes and when the federal policies at stake and the practicalities of litigation make that rule a significantly more appropriate vehicle for interstitial law making." 462 U.S. at 172, 103 S.Ct. at 2294 In DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151, 103 S.Ct. 2281, 2293, 76 L.Ed.2d 476 (1983), the employee's right of action derived solely from the NLRA, which deprives employees of the ability to bargain individually with employers but imposes on unions a corresponding duty of fair representation. 103 S.Ct. at 2290 n. 4; see also, e.g., Vaca v. Sipes, 386 U.S. 171, 177, 87 S.Ct. 903, 909, 17 L.Ed.2d 842 (1967). In order for a court to grant an employee relief from the actions of one or both of the actual parties to the arbitration, therefore, the employee must claim and prove that the union did not fairly represent him. 103 S.Ct. at 2290-91. See also, e.g., Anderson and Moore v. Norfolk and Western Railway Co., 773 F.2d 880 (7th Cir.1985). The practicalities of this kind of suit mandate a longer statute of limitations than the 90-day period typically provided by the states. As the Court noted in DelCostello, "the employee will often be unsophisticated in collective-bargaining matters, ... and will be called upon, within the limitations period, to evaluate the adequacy of the union's representation, to retain counsel, to investigate substantial matters that were not at issue in the arbitration proceeding, and to frame his suit." Id. 103 S.Ct. at 2291. At the same time, however, the national interest in protecting consentual labor dispute resolution from delayed attack prompted the Court in another case, when forced to choose between 90-day and 6-year state statutes of limitations, to opt for the shorter period. United Parcel Service, Inc. v. Mitchell, 451 U.S. 56, 64, 101 S.Ct. 1559, 1564, 67 L.Ed.2d 732 (1981). DelCostello thus represents a recognition that the NLRA's six-month period, which was congressionally designed to accommodate the very balance of interests at stake in DelCostello, was more appropriate than any of the state alternatives. 103 S.Ct. at 2294.