does not mean that an employee may not sue a union for the union’s independent breach of a collective bargaining agreement unless the employee can establish that the union also breached its duty of fair representation. When the employee alleges that the union itself has breached an obligation to the employee under the collective bargaining agreement, the policy reasons for requiring a violation of the duty of fair representation in the hybrid suits no longer apply. Proof of the contractual violation alone should suffice, without requiring the employee also to establish that the union violated its duty of fair representation with conduct that was arbitrary, discriminatory or in bad faith. Cf. United Steelworkers v. Rawson, 495 U.S. 362, 374, 110 S.Ct. 1904, 1912, 109 L.Ed.2d 362 (1990) (<HOLDING>); IBEW v. Hechler, 481 U.S. 851, 864-65 & n. 7,
holding that union policy of furnishing only its members with legal counsel in connection with grievances under collective bargaining agreement violated unions duty of fair representation under federal service labormanagement relations statute holding that a union may breach its duty of fair representation by rejecting an employees interpretation of the collective bargaining agreement if the unions interpretation is itself arbitrary or unreasonable holding that an employee may sue for breach of a collective bargaining agreement without the union holding that union could contractually undertake in collective bargaining agreement other duties towards member employees in addition to statutorilyimposed duty of fair representation holding that petitioners remedy under title vii of the civil rights act was in addition to remedies available under the collective bargaining agreement in force between his employer and his union