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In 1959 Congress passed the Labor-Management Reporting and Disclosure Act (LMRDA).' The goals of the Act were to guarantee the political and civil rights of union members within their unions and to make union officers more responsive to members' welfare. 2 Title IV of the Act established standards to ensure free and democratic union elections3 and empowered the Secretary of Labor to bring suit to overturn elections upon a member's complaint that those standards were breached. Congress made the Secretary's suit the

Dunlop v. Bachowski and the Limits of Judicial Review under Title IV of the LMRDA: A Proposal for Administrative Reform