Jibson v. Michigan Education Ass'n-NEA

BOYCE F. MARTIN, Jr., Circuit Judge.

This case involves yet another challenge to a labor arrangement sanctioned by the Michigan Public Employment Relations Act. Under the Act, any public school employee who is not a member of his or her local education association may be required nonetheless to pay a service fee to the local association for its costs of statutory exclusive representation. Mich.Comp.Laws § 423.211. In Abood v. Detroit Board of Education, 431 U.S. 209, 97 S.Ct. 1782, 52 L.Ed.2d 261 (1977), the Supreme Court found this plan to be constitutionally sound, but recognized both the…