	Introduction

In 1988, the Supreme Court, in Communications Workers of America v. Beck (hereinafter referred to as Beck ), ruled against organized labor and held that non-union employees could not be required to pay full union dues if some of those funds were to be used for activities unrelated to collective bargaining. It required notification to federal contractor non-union employees that their union dues may not be used to support political activities that they oppose. Prior to the Beck and Lehnert decisions, the Supreme Court regularly revisited this issue in a line of decisions which held that labor unions cannot use dissenting non-union employees' dues for political and ideological activities outside the scope of the activities related to collective bargaining. Such cases include: (1) International Association of Machinists v. Street , 367 U.S. 740 (1961); (2) Railway Clerks v. Allen , 373 U.S. 113 (1963); (3) Abood v. District Board of Education, 431 U.S. 209 (1977); (4) Ellis v. Brotherhood of Railway Clerks, 466 U.S. 435 (1984); and (5) Chicago Teachers Union v. Hudson, 475 U.S. 292 (1986). Another type of a union security agreement is the agency shop agreement whereby the employees do not have to join the union or have full union membership in good standing within thirty days, but must support the union by paying a sum of money equivalent to union dues in order to retain employment. The union established a three-stage procedure with the union's administration to consider non-members' objections to such deductions.
Under union shop agreements, labor unions must establish strict safeguards and procedures for ensuring that non-members' dues are not used to support certain political and ideological activities that are outside the scope of normal collective bargaining activities. The "union shop" or "agency shop" agreement essentially provides that employees do not have to join the union, but must support the union in order to retain employment by paying dues to defray the costs of collective bargaining, contract administration, and grievance matters.
In a line of decisions, the Supreme Court has addressed this issue and has concluded that compulsory union dues of non-members may not be used for political and ideological activities that are outside the scope of the unions' collective bargaining and labor-management duties when non-members object to such use. Seven Supreme Court decisions have held that union dues exacted from dissenting non-members may not to be used for political and ideological purposes and must be expeditiously refunded to dissenting non-members according to proper procedural safeguards: (1) International Association of Machinists v. Street, 367 U.S. 740 (1961); (2) Railway Clerks v. Allen, 373 U.S. 113 (1963); (3) Abood v. District Board of Education, 431 U.S. 209 (1977); (4) Ellis v. Brotherhood of Railway Clerks, 466 U.S. 435 (1984); (5) Chicago Teachers Union v. Hudson, 475 U.S. 292 (1986); (6) Communications Workers of America v. Beck, 487 U.S. 735 (1988); and Lehnert v. Ferris Faculty Association, 500 U.S. 507 (1991).