collect fees to reflect the benefits from collective bargaining: fees could not be used for spending on political activities without the member's consent. Unions have always been entitled to publicly campaign for members of Congress or presidential candidates that support labor rights. But the urgency of political spending was raised when in 1976 Buckley v Valeo decided, over powerful dissents of White J and Marshall J, that candidates could spend unlimited money on their own political campaign, and then in First National Bank of Boston v. Bellotti, that corporations could engage in election spending. In 2010, over four dissenting justices, Citizens United v FEC held there could be essentially no limits to corporate spending. By contrast, every other democratic country caps spending (usually as well as regulating donations) as the original Federal Election Campaign Act of 1971 had intended to do. A unanimous court held in Abood v Detroit School Board that union security agreements to collect fees from non-members were also allowed in the public sector. However, in Harris v Quinn five US Supreme Court judges reversed this ruling apparently banning public sector union security agreements, and were about to do the same for all unions in Friedrichs v California Teachers Association until Scalia J died, halting an anti-labor majority on the Supreme Court. In 2018, Janus v AFSCME the Supreme Court held by 5 to 4 that collecting mandatory union fees from public sector employees violated the First Amendment. The dissenting judges argued that union fees merely paid for benefits of collective bargaining that non-members otherwise received for free. These factors led campaign finance reform to be one of the most important issues in the 2016 US Presidential election, for the future of the labor movement, and democratic life. Collective bargaining Since the industrial revolution, collective bargaining has been the main way to get fair pay, improved conditions, and a voice at work. The need for positive rights to organize and bargain was gradually appreciated after the Clayton Act of 1914. Under §6, labor rights were declared to be outside of antitrust law, but this did not stop hostile employers and courts suppressing unions. In Adair v United States, and Coppage v Kansas, the US Supreme Court, over powerful dissents, asserted the Constitution empowered employers to require employees to sign contracts promising they would not join a union. These "yellow dog contracts" were offered to employees on a