Thanks to a series of lawsuits filedwith Foundation legal aid, home-basedchild and personal care providers from

FoundationActionFoundationAction

Vol. XXXV, No. 1 8001 Braddock Road • Springfield, Virginia 22160 www.nrtw.org January/February 2015

The bi-monthly newsletterof the National Right to Work

Legal Defense Foundation, Inc.

SYRACUSE, NY - With free legal assis-tance from National Right to WorkFoundation staff attorneys, several NewYork home-based childcare providershave filed a federal lawsuit challenging astatute that subjects them to compulso-ry unionization. The providers’ lawsuitalso seeks a refund of illegally-seizedunion dues.

In early December, Mary Jarvis andnine other providers filed the suit in U.S.District Court for the Northern Districtof New York. The lawsuit seeks to buildon the landmark, Foundation-wonSupreme Court victory in Harris v.Quinn from earlier this year.

Jarvis and the other providers arechallenging the AFSCME-affiliatedCivil Service Employees Association(CSEA) union’s claim to exclusively rep-resent thousands of caregivers outsideNew York City who operate home-basedchildcare businesses. Union officialshave also been empowered to collectdues from all eligible childcareproviders, even those who want nothingto do with the union.

“[The union] said, ‘You can say you’renot a member, but we’re gonna take yourmoney’,” said plaintiff Charlese Davis,who’s been a child care provider for 25years. “That’s exactly what was said tome.”

“New York childcare providersshouldn’t be forced to pay union dues oraccept the CSEA’s unwanted ‘representa-tion’,” said Patrick Semmens, VicePresident of the National Right to Work

Foundation. “We hope the DistrictCourt recognizes that caregivers’ funda-mental First Amendment rights takeprecedence over union bosses’ desire forforced dues.”

Applying the Harrisvictory to the states

A 2007 executive order signed by dis-graced former Governor Eliot Spitzerset the stage for this latest unionizationscheme. New York childcare providersreceive a small remittance from the stateto assist their caregiving activities, andSpitzer’s order made union “representa-tion” and dues payment mandatory forchildcare providers who receive a statesubsidy.

See CHILDCARE LAWSUIT page 8

Foundation Helps Childcare Providers Fight New York Unionization SchemeLegal challenge builds on Foundation’s precedent-setting Harris Supreme Court victory

Charlese Davis, a Foundation-assisted childcare provider from upstate NewYork, was told she had to pay full dues even if she didn’t join the union.

IN THIS ISSUE

Local Confectioner FightsUnion Bosses’ SweetheartDeal with Employer

Foundation Helps Civil ServantsFile Lawsuit Against SEIU, SantaClara County

Obama NLRB AggressivelyPushes ‘Card Check Lite’ viaBureaucratic Fiat

2

3

4

6

7 Featured Article: NLRB BudgetDoubles as Workload Plummets

Judge’s Ruling Advances AirlineWorkers’ Landmark Forced DuesLawsuit

2 Foundation Action January/February 2015

Rev. Fred Fowler Chairman, Board of TrusteesPatrick Semmens Vice President and Editor-in-ChiefRay LaJeunesse, Jr. Vice President and Legal DirectorMark Mix President

The Foundation is a nonprofit, charitable organization providing free legal aid to employeeswhose human or civil rights have been violated by abuses of compulsory unionism. All contributions

to the Foundation are tax deductible under Section 501(c)(3) of the Internal Revenue Code.

Distributed by theNational Right to Work Legal Defense Foundation, Inc.

8001 Braddock Road, Springfield, Virginia 22160www.nrtw.org • 1-800-336-3600

Foundation Action

SANTA CLARA, CA - Two Santa ClaraValley Medical Center employees havefiled a federal class-action lawsuitagainst a local union and the county thatemploys them, seeking to expand publicemployees’ right to refrain from payingunion dues for politics.

With free legal assistance fromNational Right to Work Foundation-provided attorneys, Santa Clara countyemployees Jeffrey Lum and Andrew Lifiled the lawsuit in California DistrictCourt in early December.

Lum and Li are not union members,but the Service Employees InternationalUnion (SEIU) Local 521 has acquiredmonopoly bargaining privileges fortheir workplace. Because Californiadoes not have a Right to Work law,workers can be required to pay uniondues or fees as a condition of employ-ment if their workplace is unionized.However, nonmember workers have theright to refrain from paying for unionpolitics and any other activities unrelat-ed to workplace bargaining.

Despite Lum and Li’s nonunion sta-tus, SEIU and county officials continueto deduct an amount equal to full uniondues from both employees. For up to 14months after taking full dues from theirpaychecks, SEIU officials were free toillegally spend that money on theirextensive and often radical politicaloperations.

“The SEIU’s current policy amountsto an interest-free loan to union bossesthat can be used for any number ofpolitical activities that may be contraryto the views of those forced to pay dues,”said Patrick Semmens, Vice President ofthe National Right to Work Foundation.“Nonunion workers should never haveto pay for union politics, not even in theform of an interest-free loan, which iswhy the Foundation stepped in.”

Suit builds on FoundationSupreme Court victory

This lawsuit also challenges existinglower federal court case law thatrequires nonmember public employeesto pay an amount equal to full uniondues – including the portion used forunion politics – unless they affirmative-ly object. Workers who object must alsorenew their objections annually.

In 2012, the Foundation-won Knox v.SEIU Supreme Court decision struckdown an affirmative objection require-ment for special assessments. The Courtalso indicated that it was ready toreassess whether union bosses’ forced-dues powers, which it called “somethingof an anomaly,” include the power to use“an opt-out system for the collection offees levied to cover nonchargeableexpenses.” Responding to that sugges-tion, Lum and Li’s lawsuit seeks toexpand the Knox precedent to apply toall instances in which public employeesrefrain from union membership.

“Union bosses have the government-granted power to force workers to fundtheir political activities unless workersobject – a power granted to no other pri-vate organization,” continued Semmens.“Workers shouldn’t have to go throughonerous opt-out procedures just toassert their fundamental FirstAmendment rights.”

Two Santa Clara civil servants areseeking to end automatic duesdeductions for politics by challeng-ing SEIU policies in court.

Foundation Helps Civil Servants File Lawsuit Against SEIU, Santa Clara CountyCounty employees seek to end automatic dues deductions for union politics

what’s right for them,” Manning toldThe Leader.

Union officials denied her request,and then threatened to have her fired ifshe refused to pay union dues.

With the help of National Right toWork Foundation staff attorneys,Manning filed federal unfair labor prac-tice charges against the union and thecompany with the National LaborRelations Board (NLRB). Shortly aftershe filed charges, the company backeddown and reimbursed her for lost wagesstemming from her suspension in June.Manning and her Foundation attorneysare still pursuing the charges against thecompany and the union.

“Union and company officials pun-ished this worker for exercising herrights so they could collect more forced-dues cash for union bosses’ coffers,” saidMark Mix, President of the NationalRight to Work Foundation. “Workerswill continue to face similar schemesuntil California passes a Right to Worklaw, which would ensure that unionmembership and dues payment arecompletely voluntary.”

January/February 2015 Foundation Action 3

California Confectioner Fights Union Bosses’ Sweetheart Deal with CompanyCandy company worker was suspended without pay for trying to exercise her workplace rightsOAKDALE, CA – Thanks to free legalassistance from the National Right toWork Foundation, a Modesto-areaSconza Candy Company employeereceived back pay after she filed federalcharges against a local bakers union andher employer for a litany of rights viola-tions.

After Sconza utility worker AthenaManning was hired in September 2013,company management and BakersUnion Local 125 officials failed to noti-fy her of her right to refrain from full-dues-paying union membership.Company and union officials alsoactively misled her about her obligationsto the union.

Union officials violatelaw; employee suspendedwithout pay

Because California lacks a Right toWork law, employees can be required topay union dues or fees as a condition ofemployment. However, in the NationalRight to Work Foundation-wonCommunications Workers v. Beck case,the U.S. Supreme Court held that work-ers who refrain from formal unionmembership have the right to refrainfrom paying for union boss politics andany other activities unrelated to work-place bargaining.

Furthermore, union officials mustprovide newly-hired workers withnotice of their rights to refrain frommembership and the payment of activi-ties unrelated to bargaining when seek-ing to require them to pay union dues. Ifany employee chooses not to join theunion and objects to paying full dues,union officials must provide an inde-pendently-audited breakdown of theirexpenditures to help employees deter-mine what they are obligated to pay.

In May, company management andunion officials claimed that joining theunion and paying full dues wererequired as a condition of employment.Even though union officials never pro-vided Manning with accurate informa-tion about her rights, she was notifiedby a Sconza manager on June 9 that shewas being suspended without pay fromher job for a week for failing to join andpay dues to the union.

“There’s something rotten here withthe union and Sconza,” Manning told alocal paper, The Oakdale Leader. “Theunion doesn’t take care of their employ-ees or their rights.”

Foundation attorneys helpworker assert rights

After the incident, Manning request-ed that union officials follow federal dis-closure requirements and provide herwith a verified breakdown of theirforced-dues expenditures.

“I want employees here to have infor-mation and a choice to prepare for

Sconza Candy utility worker Athena Manning filed federal charges after shewas illegally suspended without pay for a week for exercising her rights.

Photo Credit: The Oakland Leader

4 Foundation Action January/February 2015

majority of the workers indicate theirdesire to remove the union from theirworkplace. This new policy gives Griffinthe power to prosecute a company thatvoluntarily removes recognition of anunwanted union at workers’ behest evenif the company has done nothing wrong.

National Right to Work Foundationstaff attorneys are assisting workersacross the country who seek to protecttheir rights to remove unwanted unionsfrom their workplaces.

An Arlington Metals Corporationsteelworker from Franklin Park, Illinois,and a San Francisco-area Scoma’s ofSausalito restaurant worker have movedto stop Griffin from foisting unwantedunion representation back on theirrespective workplaces. Meanwhile,Chehalis, Washington, steel manufac-turer Bradken, Inc. workers seek to havetheir ballots counted to determinewhether the workers want to remove alocal Machinist union from their work-place after the NLRB blocked the count.And a Hope, Arkansas, SouthernBakeries worker asked a federal court toallow him to intervene after the federalagency tried to foist unwanted unionrepresentation back on his workplaceafter he and two-thirds of his coworkersexpressed their desire to remove theunion.

Underscoring the Board’s doublestandard, the NLRB still maintains thata company can recognize a union if amajority of workers sign union “cards”through the card check method, even asits top lawyer works to eliminate work-ers’ ability to use the same procedure tooust an unwanted union.

Obama appointees pushambush election rules

Even though the 2014 Republicanelectoral wave forced President Obama

WASHINGTON, DC - In his book TheAudacity of Hope, then-presidential can-didate Barack Obama wrote: “I owethose unions.” After Big Labor spentnearly $1 billion to get President Obamaand his forced-unionism allies elected in2008, they went right to work to pass theso-called “Employee Free Choice Act” –the sole purpose of which was to codifythe coercive and unreliable unionorganizing tactic known as “card check.”

Now, during the homestretch ofObama’s presidency, the National LaborRelations Board (NLRB) has released asteady stream of decisions and rulesdesigned to push coercive card checkunion organizing via bureaucratic fiatafter card check legislation failed inCongress.

Obama Labor Boardrolls back employee rights

Early in Obama’s first term, the pres-ident and a filibuster-proof Democraticmajority failed to pass the card checkbill. In response, Obama sought toimplement card check legislation via theadministrative powers of the NLRB andnominated union lawyers Craig Becker(a notorious card check proponent) andMark Pearce to the Board. After Becker’snomination failed in the face of biparti-san opposition in the Senate, Obamarecess-appointed him to the Board.

The Obama Labor Board soon wentto work. The new majority of Obamaappointees, including Becker, voted tooverrule the National Right to WorkFoundation-won Dana precedent.Under Dana, workers were, for the firsttime, accorded some protections againstcard check unionization, including theright to petition for a secret-ballot votein the wake of a card check forcedunionization campaign in their work-place. Becker refused to recuse himself

from the case even though he previous-ly had opposed those protections whileparticipating in the original Dana caseas an AFL-CIO union lawyer.

NLRB policy reveals cardcheck double-standard

Less than two years later, Obamanotoriously subverted the U.S.Constitution and installed pro-forced-unionism radicals Sharon Block andRichard Griffin on the Labor Board aspurported “recess” appointments whileCongress was not in recess – a move thatthe U.S. Supreme Court unanimouslystruck down as illegal.

Now, former illegal “recess”appointee Griffin, who serves as theNLRB’s General Counsel, is pushing anew policy in which union bosses canfile federal charges to block employersfrom withdrawing recognition of aunion as the workers’ monopoly bar-gaining representative even after a

Undeterred by a series of legislativesetbacks, union political operativesare now pushing to implement “cardcheck lite” through bureaucraticrule-making.

Obama NLRB Aggressively Pushes ‘Card Check Lite’ via Bureaucratic FiatObama Labor Board expands Big Labor’s privileges despite rejection from Congress, voters

to back down from reinstalling illegal“recess” nominee Sharon Block to theBoard, Obama’s substitute for Block,Lauren McFerran – a former unionlawyer and staffer to Senators TedKennedy and Tom Harken – was forcedthrough the Senate via outgoing SenateMajority Leader Harry Reid’s (D-NV)“nuclear option” during the December“lame duck” session.

McFerran’s confirmation ensures thatObama’s radical appointments will holda majority until at least August 2018and, without any fear of imperiling anymember’s successor’s nominations,opened the door for the NLRB to issuenew unionization election regulations.These new rules closely mimic cardcheck forced unionism tactics, makingunion organizing campaigns even moreone-sided.

In mid-December, the NLRB issuednew rules designed to push workers intounion ranks by ambushing them with“quick-snap” elections, which will stiflethe free speech rights of employees whomay oppose the unionization of theirworkplace. The rules also force employ-ers to hand over to union organizers thename, address, phone number, emailaddress, and shift schedule of eachemployee, exposing workers to “homevisits” and other intimidation tactics.Coupled with an NLRB ruling issuedthe day before mandating that employ-ers allow company-owned email sys-tems to be used for union organizing,the new rules open the door for cyber-bullying by union organizers

“After suffering a decisive defeat inCongress, the Obama NLRB is attempt-ing to bypass the legislative process byincrementally implementing the worstfeatures of card check forced unionism,”said Mark Mix, President of theNational Right to Work Foundation.“This is just the latest example of theBoard’s campaign to undermine workerrights, and Foundation attorneys areresearching how to legally challenge theObama NLRB’s enactment of unionbosses’ card check wish list.”

January/February 2015 Foundation Action 5

As we start 2015, Congress has yetto propose what changes will takeplace in the New Year that concerncharitable giving and tax incentives.The volatile stock market continuesto reach new highs, but remainsunstable due to the price of oilaround the world. In this environ-ment, it is crucial to explore whatyou can do to maximize your taxsaving options for the future andprovide a tax-deductible gift to theNational Right to Work Foundation.

Over the next few months, all of uswill be preparing and filing our 2014tax returns and many will considerwhat we can do to alleviate heavytax burdens in the future.Reviewing your estate plan is cru-cial for economic security for youand your loved ones. At this time,there are several options to consid-er to take advantage of making acharitable gift to the Foundation –and to assist its ongoing fightagainst the abuses of compulsoryunionism.

Gifts of cash are the most commonmethod of making a charitable gift,but many also make a gift of stock.A gift of stocks, mutual funds, orother securities that have increasedin value since their purchase isanother way to make a charitablegift to the Foundation right now.Appreciated securities are subjectto capital gains tax when they aresold. A gift of stock (held for morethan one year) may be deducted inamounts totaling up to 30 percentof your AGI limit. (Please see belowfor instructions on how to give a tax-deductible gift today.)

Now may be an ideal time to reviewall of your estate plan, but mostimportantly, your will or trust docu-

ments that give financial security toyou, your family, and the charitiesyou choose to include in your estateplan. You may wish to include theFoundation through a charitable giftannuity, charitable remainder trust,charitable lead trust, life insurancepolicy, or an outright bequest. Weencourage all of our supporters toreview their estate plans today.

Your continued investment andpartnership in the fight againstforced unionism in the workplace isdeeply appreciated. Your generosi-ty to the Foundation goes a longway toward assisting thousands ofworkers nationwide who are brave-ly standing up to union coercion inthe workplace.

We encourage you to consult yourown tax advisor or estate attorneyand receive the peace of mind thatyou have provided a will or estateplan for your loved ones and thecharities you support. If you haveany questions, or need additionalinformation on a planned gift,please contact Ginny Smith at 800-336-3600. Thank you again for yourgenerosity and have a Happy NewYear!

Make a Planned Gift in 2015 andInvest in the Future of Right to Work

Make Donations of Stock to:Bank of America, N.A.100 W. 33rd StreetNew York, NY 10001

First Credit: Merrill Lynch11951 Freedom Drive, 17th Floor

Reston, VA 20190Routing (ABA) Number: 026009593

DTC# 5198Account # 6550113516

FBO: National Right to WorkLegal Defense and Education

Foundation, Inc.Foundation Account #86Q-04155

6 Foundation Action January/February 2015

“Union bosses have abused theirextraordinary government-grantedpower to automatically compel workersto fund their political activities unlessworkers object – a power granted to noother private organization in our coun-try – for far too long,” said Mark Mix,President of the National Right to WorkFoundation. “The First Amendmentright to automatically refrain from pay-ing union dues, especially for politics, islong overdue.”

DALLAS, TX – In late November, acourageous group of airline employeeswho filed a potentially landmark lawsuitthat seeks to expand airline and railwayworkers’ right to refrain from payingdues for union politics won a federalcourt ruling granting their motion forclass certification.

With free legal assistance fromNational Right to Work Foundationstaff attorneys, five American EagleAirlines baggage handlers from Texasand four Southwest Airlines flight atten-dants from Maryland, California, andNevada filed the class-action lawsuitagainst the Transport Workers Union ofAmerica (TWUA), which enjoysmonopoly bargaining priviliges for50,000 railroad and airline workersacross the country under the jurisdic-tion of the Railway Labor Act (RLA).

The airline workers who filed the suitare not TWUAmembers but must stillaccept the TWUA as their “exclusivebargaining representative.” Moreover,the RLA empowers union officials toextract union dues from workers as pay-ment for their so-called “representa-tion,” even in Right to Work states.

Supreme Court questionsunion forced-dues powers

In 2012, the Supreme Court suggest-ed in the Foundation-won Knox v. SEIUruling that it was ready to reassesswhether union bosses’ forced-dues priv-ileges, which it called “something of ananomaly,” violate workers’ FirstAmendment rights. The Court alsoquestioned union bosses’ power to auto-matically require workers to pay fulldues unless those workers affirmativelyexercise their right to refrain.

Responding to the Court’s skepticismregarding union bosses’ forced-duespowers, the airline workers in Serna v.

Transport Workers Union of Americaseek to eliminate forced unionism acrossthe country.

Alternatively, the workers seek toexpand the Knox ruling to apply to allinstances in which railroad and airlineworkers refrain from union member-ship. If they are successful on that front,workers who do not join a union willalso automatically not pay for unionpolitical activism and other non-bar-gaining activities. Under the new stan-dard the airline employees hope toestablish, union officials would berequired to get workers’ affirmative con-sent before collecting union dues forpolitical activism.

Workers win class-actionstatus for lawsuit

A U.S. District Court for theNorthern District of Texas judge grantedthe workers’ motion for class-action cer-tification of their lawsuit in December.The judge held that all workers refrain-ing from TWUA union membership inthe past, present, and future can be partof the class.

Building on the Foundation’s Knox Supreme Court victory, a group of airlineemployees are seeking to ensure that union bosses receive consent from airand railway workers before collecting dues for political activities.

Judge’s Ruling Advances Airline Workers’ Landmark Forced Dues LawsuitReceiving class-action status an important step toward protecting workers’ First Amendment rights

Newsclips Requested

We’re always looking for newsstories that expose union cor-ruption, mismanagement, andabuse. Send articles that appear

in your local paper to:

NRTWLDFATTN: Newsclip Appeal8001 Braddock RoadSpringfield, VA 22160

Supporters can also emailonline stories to wfc@nrtw.org

The federal government’s top labor arbiter has seen itsbudget skyrocket even as its caseload plummeted torecord lows over the past three decades, according to anew study.The National Labor Relations Board, which oversees

workplace disputes and union elections, is issuing fewerdecisions and handling fewer cases than it ever has beforethanks to plummeting union membership numbers.However, that decline in work has coincided with anever-increasing budget, according to an analysis pub-lished by the National Right to Work Legal DefenseFoundation.“Since 1980, fiscal year total case intake (representa-

tion cases and unfair labor practice cases) is down 58%;published decisions are down 85%; appropriations in2014 dollars are up 98%,” the report says.Staffing levels no longer reflect the workload that the

agency handles, according to study author and formerNLRB board member John Raudabaugh.The agency spends four times more on its workforce

per decision issued than it historically did and it continuesto maintain local offices across the country even as rightto work laws have spread and union membership has beenreduced from a peak of 30 percent in the 1950s to about10 percent today.“They’ve made no serious effort to consolidate local

and regional offices,” Raudabaugh said in a phone inter-view. “The board needs to be encouraged just like anyother government agency to be run efficiently and heldaccountable to the taxpayer.”The NLRB declined to comment for this story.A 2013 agency report said the NLRB reduced local

offices from 32 to 26, according to the report. It plans tostreamline its operations through more video conferenc-ing and digitized case management files. The report con-cluded that the NLRB was effectively streamlining itscaseload and efficiently clearing its docket.“The NLRB established two performance measures. In

particular, the timeliness and quality of case processing,from the filing of an ULP charge to the closing of a caseupon compliance with a litigated or agreed-to remedy, arethe focus of those performance measures,” the report said.

Raudabuagh said that the agency’s measures do notgive an accurate picture of efficiency. The board shouldbase its standards on how much money is used per case,rather than simply measuring how fast cases are handled.A lower caseload has led to increased trips and redundantactivity designed to “educate people about a statute [theNational Labor Relations Act] that has been around since1935,” Raudabaugh said.The decline in caseload has not stopped the agency

from complaining about the “severe austerity” thatoccurred in 2013 when its budget was reduced by 5 per-cent to about $264 million.“The reduction in Agency funding combined with an

increase in caseload, wages, and other non-discretionarycosts, such as rent and security, along with requiredspending on essential programs, initiatives and resourcesthat have been deferred or curtailed and those that mustbe renewed…will cause drastic measures to be undertak-en,” the report said.Raudabaugh said that the agency’s handling of its

budget demonstrates that it is not serious about being agood steward of taxpayer dollars.“Their work is slowly going down and yet the board is

not adjusting to lower intake,” Raudabaugh said. “Weneed to cut through all the ridiculousness and focus onhow many people do we really need to appropriately han-dle the NLRB’s mission.”

This article was first published in The Washington FreeBeacon on 12/3/14.

January/February 2015 Foundation Action 7

NLRB’s Budget Doubles as Workload Plummets

NATIONAL RIGHT TO WORKFEATURED NEWS ARTICLE

across the country have challenged sim-ilar unionization schemes in severalstates, including Illinois, Massachusetts,Minnesota, and Michigan.

Last Summer, the U.S. SupremeCourt issued a landmark ruling inHarris v. Quinn that struck down theIllinois scheme, holding that individualswho receive state subsidies based ontheir clientele cannot be forced to paycompulsory union fees. The next day,the Court cleared the path for 50,000home childcare providers in Michiganto receive a refund of union dues illegal-ly confiscated under that state’s now-defunct homecare unionization scheme.

Building on the favorable Harrisprecedent, Foundation attorneys arguethat the New York scheme violates theproviders’ First Amendment right tochoose who they associate with to peti-tion the government.

People shouldn’t be forced to be partof a club they don’t want to join, saidMary Jarvis, another Foundation-assist-ed plaintiff. “We want to keep ourmoney in our day cares, doing things forour children.”

“Forcing New York childcareproviders to pay dues and acceptmandatory union ‘representation’ is aviolation of their First Amendmentrights,” said Semmens. “This latestscheme, which forces small businessowners into union ranks, is completelycontrary to the principle of free associa-tion.”

“Fortunately, our landmark SupremeCourt victory in Harris v. Quinn givesFoundation staff attorneys the tools tochallenge homecare unionization drivesin states across the country,” continuedSemmens. “We hope the New YorkDistrict Court takes note of the SupremeCourt’s Harris decision, which stronglyaffirms homecare providers’ FirstAmendment rights, and rules accord-ingly.”

Dear Foundation Supporter,

The American people spoke loud and clear on November 4 against Big Labor’sradical forced-dues agenda.

But you and I can’t expect the Obama Administration to heed their message.

Barack Obama and his “team” have never been shy about paying back theirunion-boss benefactors through the National Labor Relations Board, Departmentof Labor, and other powerful agencies in the executive branch.

I fear that the Obama Administration will do the most damage yet to workerfreedom now that Obama himself doesn’t have to face the voters again and BigLabor can’t force its agenda through Congress.

Just a month after the voters spoke in the midterm elections, the Obama LaborBoard rammed through new union certification election procedures that willempower union bosses to ambush workers with quick-snap elections and exposethem to many of the same abuses as card check forced unionism.

Those of us committed to the cause of freedom must be prepared for moretooth-and-nail battles against Big Labor’s handpicked bureaucrats and schemeslike that one.

I’m grateful knowing the National Right to Work Foundation has supporterslike you enabling us to fight back in court.

Thanks to your help, Foundation staff attorneys have already fought back – andwon – against some of the Obama Administration’s most egregious union-bosspower grabs.

Your continued generosity enables us to stay on guard. Thank you.

Sincerely,

Mark Mix

8 Foundation Action January/February 2015

Message fromMarkMix

PresidentNational Right to WorkLegal Defense Foundation

Childcare Lawsuitcontinued from page 1