Bernadette Tavernor v. Illinois Federation of Teachers and University Professionals of Illinois Local 4100

DIÁNE P. WOOD, Circuit Judge.

Two points in the area of public labor relations are by now well established. First, public employers may have a collective bargaining agreement with a union that requires all employees, union members and nonmembers alike, to contribute to the union’s representational activities— that is, the agreement may include a “union security clause.” Second, those who object to nonrepresentational activities of the union have the right to pay fees that exclude contributions to those activities'— so-called “fair share fees.” See Chicago Teachers Union Local No. 1 v. Hudson,…