1. 1980.Golden v. Local 55, Firefighters817 See for example 633 F. 2d Although it was found that the union did not violate Title VII nor Section 1981, the important point to be made from this case is that city employees have a cause of action under these statutes against their unions for a DFR breach. It should further be noted, however, the U.S. Supreme Court recently ruled in Jett v. Dallas Ind. School District (57 Law Week 4858, June 20, 1989) , that when a state or municipality is involved, Section 1983 of the Civil Rights Act of 1871 provides an exclusive federal remedy for violations of rights guaranteed by Section 1981. The applicability of this ruling to unions remains to be seen
2. Because the DFR doctrine is looked at more as a policy tool in this article, technical aspects of the doctrine are not addressed here. As such, this article does not examine, for example, whether there is an actual DFR breach
3. Schlei, Barbara L. and Grossman, Paul. 1983.Employment Discrimination Law, 2d, 628Washington, D.C.: Bureau of National Affairs.