were used for expenses related to collective bargaining. Unions may not use dues of union objectors to finance political or ideological activities. Chicago Teachers Union v. Hudson, 475 U.S. 292 (1986)- The Court established rules regarding the collection of agency fees from public employees who object to the union- 1) employees must be provided with a financial accounting of the forced dues, 2) employees are entitled to a prompt and impartial review of the accounting, and 3) amounts reasonably in dispute may be escrowed during said review. Lehnert v. Ferris Faculty Association, 500 U.S. 507 (1991)- The Court further expounded on the rules regarding agency fees to only include those activities "germane" to collective-bargaining activity, are justified by the government's interest in labor peace and avoiding "free riders", and do "not significantly add to the burdening of free speech that is inherent in allowance of an agency or union shop." Agency fees may include a pro rata share of otherwise chargeable expense related to the state and national union affiliate. These fees may not include other expenses not directly related to the employee's bargaining unit or contract ratification, such as litigation, lobbying, and public relations. Davenport v. Washington Education Association, 551 U.S. 177 (2007)- The Court unanimously upheld a Washington state law requiring affirmative consent from non-members of the union before using their agency fees for election-related activities. Knox v. SEIU, 567 U.S. 298 (2012)- Similarly to Davenport, unions must provide a Hudson notice of a special assessment or dues increase and must receive affirmative consent from non-members before collecting said assessment or dues increase. Harris v. Quinn, 573 U.S. ___ (2014)- In a 5–4 decision, the Court refused to extend Abood's reasoning to home care personal assistants paid by Medicaid. The court found that the reasoning used in Abood to justify requiring non-union members to pay agency fees does not extend to the personal assistants because they are not similarly situated to full-fledged state employees- they do not enjoy the benefits of state employment and their employment is controlled by the person to whom they provide aid, not the state. Therefore, the First Amendment rights of the personal assistants are abridged by being required to pay agency fees to a union they do not wish to join or support. Janus v. AFSCME, 585 U.S. ___ (2018)- Building on Harris and Knox, the Court found that the payment of agency