In Byrd v. Am. Fed'n of State, County, and Municipal Employees, Council 62, 781 N.E.2d 713 (Ind. Ct. App. 2003), the Indiana Court of Appeals held that a former governor's executive order, which provided that certain employees had the right to refrain from assisting any employee organization, did not forbid the collection of "fair share" fees, which the court distinguished as fees that "assist the Employees themselves." 781 N.E.2d at 721. Thus, the court upheld a more recent executive order, which required the employees to pay "their fair share of the costs of providing Union representation, in an amount not exceeding eighty-five (85%) of the dues required to be paid by employees who are members of the Union." Id. at 717.