This generally requires evidence of discriminatory animus on behalf of the union. See Mortensen v. Hibbing Taconite Co., No. CIV. 09-706 ADM/RLE, 2010 WL 2243557, at *7 (D. Minn. June 1, 2010) (collecting cases). Thus, in this case, Plaintiff must show Local 518 failed to take any other action beyond referring him to another company because of his disability.