Dowty v. Pioneer Rural Electric Cooperative, Inc.

How later courts describe this case

• excessively broad class complaint alleging generalized racial discrimination claims does not satisfy notice requirements of American Pipe
• limitations period begins to run when plaintiff knows or should have known of the union’s alleged breach
• court erred in ordering restitution in an amount not to exceed $787,000, the loss figure to which the parties had stipulated, where defendant was convicted on an indictment alleging specific losses of only $46,250
• limiting restitution to amounts alleged in indictment
• hybrid § 301 unfair representation claim