A discussion of the opposing theories underlying the alternatives to intervention by interested employees in grievance arbitrations. The theory espoused by one of the principal proponents, Professor Clyde W. Summers, that the individual employee has the right to sue the employer separately for breach of contract, is contrasted with the theory espoused by then Solicitor General, Archibald Cox, that the individual employee has no right to force an employer to go to arbitration and that the individual is not a party to the arbitration and cannot sue the employer for breach of contract. The author also discusses a compromise position between the opposing theories and a case for intervention.