WL 642930, at *4 (S.D.N.Y. Sept. 18, 1998)). Here, the Complaint does not allege any facts sufficient to meet this threshold. II. Breach of Constitution Construing the Complaint in the most favorable light to Hosokawa, her claim for breach of the Union constitution raises two distinct issues: SAG-AFTRA breached its constitution (1) by ignoring Hosokawa’s upgrade claims, and (2) threatening to review her membership. (See Compl. ¶¶ 55(A), 79, 84.) Neither allegation suffices. First, a breach of a union constitution claim that involves the “settlement of disputes” under a collective bargaining agreement and are factually analogous to duty of fair representation claims are subject to the same six-month limitations period. See Legutko v. Local 816, IBT, 853 F.2d 1046, 1047 (2d Cir. 1988) (<HOLDING>); Sanders v. Kiley, No. 91-CV-6320 (KMW), 1995
holding that sixmonth statute of limitations period for filing unfair labor practice charges applies to employees action for breach of the duty of fair representation holding intentional conduct without rational basis is arbitrary breach of duty of fair representation holding that breach of good faith and fair dealing claim requires showing of breach of contract holding that sixmonth limitations period established in delcostello applies to a claim for breach of the duty of fair representation brought only against a union holding that sixmonth duty of fair representation statute of limitations applicable to claim alleging breach of union contract