Under the governors’ scheme, if amajority of caregivers in a “bargainingunit” had voted for unionization, all

FoundationActionFoundationAction

Vol. XXXIV, No. 5 8001 Braddock Road • Springfield, Virginia 22160 www.nrtw.org September/October 2014

The bi-monthly newsletter of the National Right to Work

Legal Defense Foundation, Inc.

WASHINGTON, DC – On June 30,2014, the United States Supreme Courtissued a landmark ruling in Harris v.Quinn, striking down a coercive union-ization scheme implemented by IllinoisGovernor Pat Quinn and his disgracedpredecessor, Rod Blagojevich.

The Harris case was argued byNational Right to Work Foundationstaff attorneys for eight Illinois home-care providers who opposed unioniza-tion. The case marks the 17th timeFoundation attorneys have arguedbefore the highest court in the land.

The Court's ruling struck down theIllinois unionization scheme, holdingthat individuals who receive state subsi-dies based on their clientele cannot beforced to pay union dues. The Court'sruling renders unconstitutional similarforced-dues homecare unionizationschemes in at least 14 other states.

"We celebrate knowing that Illinoismoms linked arms and refused to bebullied," said lead plaintiff Pam Harris."Families in Illinois can relax knowingtheir homes are safe from being a unionworkplace and there will be no thirdparty intruding into the care we provideour disabled sons and daughters."

“After a long legal struggle, eightcourageous Illinois care providers haveestablished a precedent that protects notonly their First Amendment rights, butthe rights of caregivers across the coun-try,” said Mark Mix, President of theNational Right to Work Foundation.“Forcing parents and other care

providers into union ranks is inimical tothe idea of freedom of association, andwe applaud the Supreme Court for rec-ognizing that fact.”

Unionization drives under-mine caregivers’ rights

The Harris case stemmed from a fed-eral class-action lawsuit challenging theconstitutionality of a law approved byBlagojevich in 2003 and an executiveorder later signed by Quinn. The gover-nors designated individuals who offerin-home care to disabled persons receiv-ing state subsidies as “public employees”for the purpose of subjecting them tocoercive unionization.

See SUPREME COURT WIN page 8

VICTORY! Supremes Strike Down Homecare Unionization SchemeFoundation attorneys plan to use Harris win to challenge homecare unionization nationwide

With the help of Foundation staff attorneys, Chicago-area caregiver PamHarris won an important precedent against coercive unionization.

IN THIS ISSUE

High Court Clears Path forMichigan Care Providers to WinBack Money

Teamster Bosses to Finally Pay Worker Over $50K in Damages

Supreme Court Strikes DownObama’s Illegal NLRB ‘Recess’Appointments

2

3

4

6

7 Foundation Fights Push toUnionize College Sports

Minnesota Caregivers FileLawsuit Against CoerciveUnionization Drive

2 Foundation Action September/October 2014

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

TULSA, OK – After nearly a decade ofstonewalling and legal wrangling,Teamster union bosses have finallyagreed to pay former Interstate BakeriesWonder Bread/Hostess delivery driverKirk Rammage $51,500 for discriminat-ing against him.

Eight years ago, Foundation staffattorneys helped Rammage file chargeswith the National Labor Relations Board(NLRB) against Teamster Local 523union officials for insisting thatRammage lose his seniority during amerger. The Teamsters also forcedRammage to commute to a new worklocation more than 70 miles away.

Rammage was the single nonunionsales representative with a DollyMadison facility in Ponca City for over15 years before his division was com-bined in 2005 with WonderBread/Hostess. Although the companywanted to protect Rammage’s seniorityduring the merger, Teamster officialsdemanded that he be put at the bottomof the seniority roster.

After Rammage filed charges againstthe union, the NLRB ruled against theTeamsters’ discriminatory policy. ButRammage’s legal battle wasn’t over.

Supreme Court rejectedunion twice

On an appeal filed by Teamster unionlawyers, the U.S. Court of Appeals forthe Tenth Circuit upheld the NLRB’sdecision. Those rulings were later nulli-fied by the U.S. Supreme Court in 2009on the ground that the Board lacked athree-member quorum at the time of itsdecision.

The case then went back to theNLRB. The NLRB revisited the facts ofthe case and again concluded that unionofficials broke the law. The TenthCircuit upheld the NLRB ruling againand slapped Teamster Local 523 withmonetary sanctions for the frivolousnature of the union’s lawyers’ secondappeal. Teamster union lawyersappealed the case to the Supreme Courtagain, but the Court declined to take thecase.

An NLRB Administrative Law Judgedetermined that Rammage was entitledto $47,337 in back pay and reimburse-ments, plus interest. After unionlawyers filed objections, a three-mem-ber panel of the NLRB upheld the rul-ing, forcing Teamster bosses to finallyagree to pay damages and interest total-ing $51,500.

“Justice delayed is justice denied, andMr. Rammage has been denied justicefor far too long,” said Ray LaJeunesse,Vice President of the National Right toWork Foundation. “After two appeals tothe Supreme Court, we are happy toreport that Mr. Rammage will finallyreceive what has long been owed.”

After an eight-year legal fight, Teamster union bosses have finally agreed topay Kirk Rammage over $50,000 in damages.

Teamster Bosses to Finally Pay Worker Over $50K in DamagesUnion twice went to Supreme Court to defend discriminatory scheme during 8 year legal fight

September/October 2014 Foundation Action 3

High Court Clears Path for Michigan Care Providers to Win Back MoneyGovernment union bosses took in over $4 million in dues from 50,000 childcare providersWASHINGTON, DC – In the wake ofthe National Right to Work Foundation’slatest U.S. Supreme Court victory (Seecover story), the Supreme Courtannounced on the last day of the currentterm that it has vacated the decision of alower court and remanded a federal law-suit which asks that Michigan’s 50,000home-based childcare providers receivea refund of union dues illegally takenduring a now-defunct unionizationscheme. The move tosses out a SixthCircuit Appeals Court ruling againstMichigan childcare providers, who areseeking the return of money illegallydiverted to union coffers.

In the suit, Foundation staff attorneysargue that all of Michigan’s home child-care providers should be entitled torefunds of the union dues collected afterformer Michigan Governor JenniferGranholm and a United Auto Worker(UAW) and American Federation ofState, County and Municipal Employees(AFSCME) coalition - known as theChild Care Providers TogetherMichigan (CCPTM) union - colluded toforce the state’s providers into unionranks against their will.

When this unionization scheme wasfirst announced, media reports suggest-ed that, in exchange for their specialgovernment-granted privileges to forceMichigan’s homecare providers underunion monopoly control, the unionbosses benefiting from the scheme hadcontributed to various pro-compulsoryunionism politicians in Michigan,including Governor Granholm.

Providers challengedscheme in federal court

With free legal assistance fromNational Right to Work Foundationstaff attorneys, Michigan home child-care providers Carrie Schlaud, Diana

Orr, Peggy Mashke, and Edward andNora Gross filed a federal class-actionlawsuit in 2010 against Granholm andthe CCPTM union for designatinghome childcare providers who receivestate funds as public employees solelyfor the purpose of forcing them toaccept the CCPTM’s “representation”and pay union dues.

Although less than 15 percent of40,000 eligible childcare providersreceiving state funding voted in a unioncertification election, CCPTM unionbosses were subsequently grantedmonopoly lobbying privileges and thepower to collect union dues from homechildcare providers. The union tookupwards of $4 million dollars from thechildcare providers before the schemeended.

“It’s not about the money or aboutbeing ‘anti-union;’ it’s about the princi-ple,” stated Schlaud, a home-basedprovider who employs one other personto help care for about a dozen children.“And that I had no choice in whether topay union dues.”

After filing their lawsuit, the fiveplaintiffs won a settlement withGovernor Rick Snyder ensuring thatMichigan no longer forces home child-care providers into union ranks.

However, because the providers’ lawsuitwas denied class-action status, CCPTMunion officials were not required torefund $4 million in forced union duespreviously collected from what turnedout to be over 50,000 care providers.

Supreme Court rulingopens door to dues refunds

In early July, the Supreme Courtoverturned the Seventh Circuit U.S.Court of Appeals’ decision in the caseand ordered that court to reconsider itsdenial of class-action status to the thou-sands of childcare providers. The HighCourt cited the Foundation’s recently-won Harris precedent, in which theCourt held that homecare providerscannot be forced into union dues pay-ments because of their clientele.

“The Court’s order opens the door forover 50,000 childcare providers torecover millions of dollars in illegally-seized union dues that were meant forthe children of families receiving stateassistance,” said Mark Mix, President ofthe National Right to Work Foundation.“Right to Work staff attorneys plan touse the Harris victory to help Michigancaregivers get their money back.”

Homecare provider Carrie Schlaud led the effort to strike down Michiganunion bosses’ illegal forced-dues scheme.

4 Foundation Action September/October 2014

the president to making such appoint-ments only during a congressional inter-session recess and only when the vacan-cy actually occurs during that recess.

Foundation attorneys filemandamus case to stoprogue Board

While Noel Canning was pending onappeal at the U.S. Supreme Court,Foundation staff attorneys filed a man-damus (“cease and desist”) case forJeanette Geary, a former Warwick,Rhode Island nurse, to completely shutdown the illegal Obama Labor Board.

The U.S. Supreme Court has longheld that nonmember workers cannotbe compelled to pay for union boss pol-itics. In Geary’s case, however, Obama’shand-picked Labor Board ruled thatGeary and several of her nonmembercoworkers could be forced to pay forunion boss political lobbying, includinglobbying for legislation in neighboringVermont – a ruling that flatly contra-

WASHINGTON, DC – In a victory forworkers, the U.S. Supreme Court in lateJune unanimously struck downPresident Barack Obama’s controversialpurported “recess appointments” to theNational Labor Relations Board(NLRB).

The decision may invalidate up to1,058 NLRB rulings, many of whichfavored union bosses’ forced dues pow-ers and other privileges over the inter-ests of independent-minded workers orjob providers.

Foundation staff attorneysfiled first legal challenge

On January 4, 2012, Obamaannounced that he was making threeappointments to the NLRB, includingformer union lawyer Richard Griffin,without consent from the U.S. Senateand despite the fact that the Senate wasnot officially in recess

“Obama’s recess appointments to theNLRB, despite there being no formalrecess of Congress, clearly demonstratedthat this Administration is in the pocketof Big Labor,” explained Mark Mix,President of the National Right to WorkFoundation. “Union bosses know theircoercive agenda is overwhelminglyunpopular with the American people,which is why they’ve turned to unelect-ed administrative agencies like theNLRB to push through much of whatthey cannot get by Congress.”

The appointments immediately set inmotion legal challenges to the validity ofthe Board’s pro-forced-unionism rul-ings. On January 13, 2012, NationalRight to Work Foundation staff attor-neys filed motions challenging the legal-ity of the recess appointments, makingthem among the first to challenge theillegal appointments. Foundation attor-neys continued to challenge the recess

appointments in several federal courtsin the following months, and were thefirst in the country to argue in a U.S.Court of Appeals that the appointmentswere illegal.

Appeals court handsRight to Work advocatestotal victory

However, it was another case, NoelCanning v. NLRB, that prompted a threemember panel of the U.S. Court ofAppeals for the District of Columbia tostrike down the recess appointments inJanuary 2013.

In a stunning ruling, the appealscourt adopted arguments made in anamicus curiae (“friend of the court”)brief filed jointly by Foundation staffattorneys and the Landmark LegalFoundation. The court held that therecess appointments were in violation ofthe U.S. Constitution, ruling that theRecess Appointments Clause (Article II,Section 2, Clause 2) limited the power of

The United States Supreme Court unanimously struck down PresidentObama’s unconstitutional recess appointments to the NLRB. The rulinginvalidates hundreds of pro-Big Labor decisions handed down by the Board.

Supreme Court Strikes Down Obama’s Illegal NLRB ‘Recess’ AppointmentsRight to Work Foundation attorneys argued Obama’s purported ‘recess’ appointments were invalid

September/October 2014 Foundation Action 5

dicted long-standing Supreme Courtprecedent.

Divided Supreme Courtissues unanimous ruling

Finally, on June 26, 2014, the U.S.Supreme Court upheld the NoelCanning judgment of the appeals court.

A five member majority of the Courtissued a narrow ruling holding that thepresident could make recess appoint-ments only during a recess of “sufficientlength” and that “the Senate is in sessionwhen it says it is, provided that, underits own rules, it retains the capacity totransact Senate business.”

Meanwhile, the four conservativeSupreme Court Justices concurred inoverturning the recess appointments,but like the appeals court, held that thepresident can only make recess appoint-ments during “the intermission betweentwo formal legislative sessions…[and]to fill only those vacancies that ‘happenduring the Recess’…”

As a result of the Court’s unanimousjudgment, the Board lacked a quorumfrom January 2012 to August 2013, andthe Board’s biased and decidedly pro-Big Labor rulings during that period aretherefore invalidated.

“In a victory for independent-mind-ed workers who have received unjusttreatment at the hands of Obama’s pro-forced-unionism NLRB, as many as1,058 NLRB decisions may be invalidat-ed,” said Mix. “This case underscoresthe constitutional chaos this Presidentcreated by gaming the rules for the ben-efit of union bosses.”

For breaking newsand other updates,

visit the Foundation’swebsite:

www.nrtw.org

In several recent issues ofFoundation Action we have exam-ined how you can benefit fromcareful estate planning and assistthe Right to Work cause at thesame time. We are extremelygrateful to supporters like you whoremember the Foundation in yourwill or estate.

Of course, outright gifts of cashand securities to the Foundationoffer immediate help to the millionsof Americans denied their work-place freedoms. It is a long andlonely battle, and your gift todaywill make a difference!

Have you updated your will?

Preparing a well-thought-out will ortrust instrument that is beneficialfor you, your loved ones, and yourcharitable causes can be the singlemost important estate plan you canmake – and updating your will isequally important. It is also themost important way to leave a lega-cy gift to the National Right to WorkLegal Defense Foundation and itsstrategic litigation program.

We read every day about multi-mil-lion dollar charitable bequests, butthere are countless smaller giftsthat have been arranged by sup-porters who strongly believe incharitable causes like theFoundation and wish to leave a giftin their will or estate plan. All ofthem help and are appreciated.

In addition to an up-to-date will,many supporters will consider aRevocable Living Trust which canhelp facilitate the management anddistribution of one’s property. A liv-ing trust may provide significantprobate expense savings and

speed up the process of yourestate settlement.

Below is suggested language forincluding the National Right toWork Foundation in your will ortrust instrument, or when amendingyour current will or estate plan.

I give, devise and bequeath toNational Right to Work LegalDefense and EducationFoundation, Inc., 8001 BraddockRoad, Springfield, Virginia 22160,for its general purposes:

a. The sum of $____________; orb. Name a particular investment orpiece of Property with legaldescription, custodian, etc., asapplicable; orc. ____ percent of the rest, residueand remainder of my estate, includ-ing property over which I havepower or appointment; ord. All the rest, residue and remain-der of my estate, including propertyover which I have a power ofappointment.

You must plan ahead to further yourphilanthropic goals with a gift to theFoundation or any charitable insti-tution. All of us here at theFoundation are humbled by yourgenerosity and support through aplanned gift or bequest.

We encourage you and your familyto consult your tax advisor or estateplanning attorney before making afinal decision on your estate.Please contact Ginny Smith,Foundation Director of StrategicPrograms, if you would like addi-tional information at 1-800-336-3600, ext. 3303.

Help Defend Workplace FreedomHelp Defend Workplace FreedomThrough Estate PlanningThrough Estate Planning

6 Foundation Action September/October 2014

National Right to Work Foundation.“Caregivers in states across the country,including Minnesota, are using theFoundation’s Harris victory to combatcoercive unionization drives, and wehope the Harris precedent can be usedto protect the First Amendment rightsof Minnesota caregivers.”

Childcare unionizationscheme also challenged

Meanwhile, a Foundation-assistedfederal lawsuit brought by Minnesotachildcare providers seeking to overturna state childcare unionization law wasrecently dismissed by the U.S. Court ofAppeals for the Eighth Circuit becausethe threat of unionization is not yet“imminent.”

Unlike the homecare providers, whoare facing an SEIU-led effort to pushthem into union ranks, no unionizationelection has been scheduled forMinnesota childcare providers.

MINNEAPOLIS, MN - In late August, agroup of National Right to WorkFoundation-assisted Minnesota home-care providers filed a federal lawsuitchallenging another compulsory union-ization scheme aimed at caregivers.

With the help of Foundation staffattorneys, Teri Bierman and eight otherpersonal care providers from across thestate filed the suit in U.S. District Courtagainst Governor Mark Dayton and theService Employees International Union(SEIU).

The SEIU’s unionization drive wasenabled by Governor Dayton, whopushed through legislation that desig-nates Minnesota homecare providers as“state employees” for the purpose ofunionization.

On August 27, the SEIU won amajority of votes in a write-in unioniza-tion election for Minnesota caregivers.Although nearly 27,000 care providerswere eligible to vote under the new law,only 5,782 voted. Of those, 3,543 sup-ported the SEIU, just 13 percent of thetotal number of eligible voters.

Consequently, SEIU officials are nowempowered to bargain for all 27,000Minnesota homecare providers.Caregivers who didn’t vote or votedagainst the union will now be forced toaccept the SEIU’s “representation.”

Lawsuit takes aim atMinnesota homecareunionization scheme

Bierman’s suit requests an injunctionto halt implementation of the law thatdesignates SEIU union officials asmonopoly bargaining representativesfor Minnesota homecare providers.

The suit challenges the forced-union-ism scheme on the grounds that it vio-lates the U.S. Constitution's guarantees

of free political expression and associa-tion.

As covered on the front page of thismonth’s issue of Foundation AAccttiioonn, theU.S. Supreme Court recently issued alandmark ruling on homecare unioniza-tion in Harris v. Quinn. The Harris casesuccessfully challenged a unionizationscheme that forced Illinois homecareproviders into union ranks against theirwill.

Now Foundation attorneys hope touse this new precedent to help care-givers in other states fight off coerciveunionization schemes. After examiningthe Harris decision, Right to Work liti-gators believe that the Court's rulingrenders unconstitutional homecareunionization schemes in at least 13other states.

“Over 27,000 Minnesota homecareproviders could be forced into unionranks because of an election in whichonly 13 percent of eligible caregiversactually voted for unionization,” saidPatrick Semmens, Vice President of the

Jennifer Parrish, a Foundation-assisted childcare provider from Minnesota,was interviewed on Fox Business about her opposition to the AFSCMEunion’s childcare organizing drive.

Minnesota Caregivers File Lawsuit Against Coercive Unionization DriveFoundation staff attorneys hope to leverage Harris Supreme Court victory in Minnesota

However, a Big Labor unionizationdrive is almost certainly on the horizon.The American Federation of State andCounty Municipal Employees(AFSCME) union is already collectingsignatures from childcare providers totrigger a unionization election. Based on

the Court of Appeals’ reasoning,Foundation staff attorneys plan to re-filethe lawsuit for Minnesota childcareproviders once a date for a unionizationelection has been set.

“It is outrageous that the state ofMinnesota is attempting to unionizeJennifer Parrish, who runs a small busi-ness out of her own home,” saidSemmens. “If AFSCME organizers pro-ceed with their childcare unionizationcampaign, we plan to re-file this lawsuitto defend Minnesota childcareproviders’ First Amendment rights fromcoercive unionization.”

September/October 2014 Foundation Action 7

Newsclips Requested

We’re always looking for storiesthat expose union corruptionand abuse. Send articles that

appear in your local paper to:

NRTWLDFATTN: Newsclip Appeal

8001 Braddock RoadSpringfield, VA 22160

Supporters can also emailonline stories to wfc@nrtw.org

sentation” or forcing them to pay uniondues because student athletes are notemployees.

Unlike employees, student athletesare not compensated for workplace per-formance. To take one example, manystudents “walk on” to teams without thebenefit of a scholarship.

Foundation attorneys note that theNLRB regional director’s labeling of stu-dent athletes as employees could alsoapply to college students who receivescholarships for academics, music, orthe arts. This overly-broad definitioncould leave even more students vulnera-ble to coercive unionization.

“If the Obama NLRB goes along withthis outrageous overreach, it will be thelatest in a long line of actions designedto extend union bosses’ privileges at theexpense of the individuals being forcedinto union ranks,” continued Semmens.“Although traditionally we’ve only rep-resented employees, we’d gladly providelegal assistance to student athletes whomay now be targeted by union bossesfor compulsory unionization.”

Foundation Fights Push to Unionize College SportsRight to Work attorneys file brief opposing NLRB football decisionSPRINGFIELD, VA – The NationalRight to Work Foundation recently filedan amicus curiae (“friend of the court”)brief with the National Labor RelationsBoard (NLRB) opposing the compulso-ry unionization of college athletes. Thebrief was filed in response to a rulingissued earlier this year by an NLRBregional director that designatedNorthwestern University football play-ers as employees eligible for unioniza-tion after Steelworkers union officialsfiled a petition for a unionization vote.

The Foundation’s brief points out thatsubjecting student athletes to compulso-ry unionization violates their FirstAmendment right to freedom of associ-ation. Under the NLRB regional direc-tor’s ruling, if a majority of student ath-letes in an NLRB-designated “bargain-ing unit” vote for unionization, all stu-dent athletes in that unit – even thosewho oppose the union’s presence – mustaccept the union’s bargaining over theirterms of participation in college sports.In states like Illinois, whereNorthwestern is located, this wouldeven mean that students could be forcedto pay union dues or fees as a conditionof participating in college athletics.

NLRB ruling could lead tostudent unionization

“The NLRB regional director’s rulingcould allow union officials to force stu-dents to accept union bargaining andpay union dues just to participate in col-lege sports,” said Patrick Semmens, VicePresident for the National Right toWork Foundation. “That’s a perverseway to treat student athletes, who don’tneed the added hassle of fending offaggressive union organizers.”

The Foundation’s brief goes on toargue that the NLRB has no interest inforcing students to accept union “repre-

Big Labor operatives have decidedthat college athletes are the nextfrontier in union organizing.

“It is outrageous that thestate of Minnesota is

attempting to unionizeJennifer Parrish, who

runs a small business outof her own home.”

caregivers would have been forced topay union dues and accept the union’s“representation,” even those whoopposed the union’s presence.

“If we accepted Illinois’ argument”that homecare workers can be forced topay union dues, wrote Justice Samuel A.Alito Jr. in his majority opinion, “wewould approve an unprecedented viola-tion of the bedrock principle that,except perhaps in the rarest of circum-stances, no person in this country maybe compelled to subsidize speech by athird party that he or she does not wishto support.”

Precedent can be used tochallenge similar schemes

As more and more employeesbecome disenchanted with Big Labor,union operatives have turned to coer-cive organizing schemes to push work-ers into their forced-dues-paying ranks.Homecare unionization drives are justthe latest – and most visible – exampleof this tactic.

Over the past several years, aggres-sive union organizers have pushed forhomecare unionization in at least 21states. Foundation litigators are alreadyhelping care providers challenge thesecampaigns in Minnesota, Michigan, andMassachusetts, as well as Illinois. Afterexamining the decision, Right to Workstaff attorneys believe that Harris can beused to challenge the constitutionality ofhomecare unionization schemes acrossthe country.

“The scope of the Harris decisiongoes well beyond the rights of homecareproviders in Illinois,” continued Mix.“We look forward to leveraging thislandmark Supreme Court decision toensure that no caregiver is forced to joinor pay dues to a union against his or herwill.”

Dear Foundation Supporter:

The Supreme Court of the United States receives about 10,000 petitions for awrit of certiorari every year. In a given year, the High Court will only hear oralargument in 70 or 80 cases.

Thanks to the dedicated support of concerned citizens like you, yourNational Right to Work Foundation has reached the very top of the legal summitseventeen times. That’s truly unparalleled success.

And it’s a privilege to find ourselves at the very tip of the spear fighting forone of the most vital rights in our constitutional republic.

The recent Harris v. Quinn decision is just the latest in a string of precedent-setting Foundation victories.

As I look back at all that we’ve accomplished since our founding in 1968, Ibelieve the best may be yet to come.

In Harris, Foundation staff attorneys asked the nine Supreme Court Justicesto consider whether government-sector forced unionism is compatible with theFirst Amendment.

While the Court freed in-home healthcare providers from being forced tosubsidize union bosses, it declined to issue a broader ruling protecting the Rightto Work for all civil servants.

But Justice Samuel Alito's opinion strongly suggests a majority of the Courtmay do so in the future.

In great detail, Justice Alito articulated how the Court's reasoning in pastforced-dues cases “is questionable on several grounds.”

Such a pronouncement from a majority of the Court was unthinkabledecades ago.

That just goes to show you how far we’ve come thanks to the generosity ofour supporters.

Sincerely,

Mark Mix

8 Foundation Action September/October 2014

Message from Mark Mix

PresidentNational Right to WorkLegal Defense Foundation

Supreme Court Wincontinued from page 1