John Marshall Harlan II,
Glover v. St. Louis-San Francisco Railway Company…
“ Texas & N.O.R. Co., 242 F.2d 230 (1957) , decided by the Fifth Circuit some years before its decision in the present case, also supports today's holding that the federal courts may grant railroad employees ancillary relief against an employer who aids and abets their union in breaching its duty of fair representation. A contrary result would bifurcate, and needlessly proliferate, litigation. ”
