their union membership status, and the employee need not join the union. However, all non-union employees must pay a fee (known as the "agency fee") to the union to cover the costs of collective bargaining (and, in some countries, other fees as well). An employee who resigns from the union may not be dismissed but must pay the agency fee. Fair share provision—The employer may hire anyone regardless of their union membership status, and the employee need not join the union. However, all non-union employees must pay a fee (known as the "fair share fee") to the union to cover the costs of collective bargaining. An employee who resigns from the union may not be dismissed but must pay the fair share fee. In public sector collective bargaining, where the agency shop is often outlawed, the fair share provision (almost identical to the agency fee) may be negotiated instead. Dues checkoff—A contract between the employer and union where the employer agrees to collect the dues, fees, assessments, and other monies from union members and/or non-members directly from each worker's paycheck and transmit those funds to the union on a regular basis. Janus v. AFSCME Janus v. American Federation of State, County, and Municipal Employees, Council 31, _ US _ (2018) is a US labor law case, concerning whether governments violate the First Amendment when they require their employees to pay fees to a union as a condition of employment. In February 2015, Illinois Republican Governor Bruce Rauner filed suit, claiming that fair-share agreements are unconstitutional and a violation of the First Amendment right to free speech. In March 2015, three government workers from Illinois represented by attorneys from the Illinois-based Liberty Justice Center and Virginia-based National Right to Work Legal Defense Foundation took legal action to intervene in the case. In May 2015, Rauner was dropped from the case, after a federal judge ruled that the governor did not have standing to bring such a suit, but the case proceeded under a new name, Janus v. AFSCME. The case is named after Mark Janus, an Illinois child support specialist covered by a collective bargaining agreement. Janus claimed that he should not need to pay fees to the American Federation of State, County and Municipal Employees because doing so constitutes paying for political speech with which Janus disagrees. This became permissible after a 1977 decision by the US Supreme Court in