In Abood v. Detroit Bd. of Educ., 431 U.S. 209, 97 S. Ct. 1782, 52 L. Ed. 2d 261 (1977), the Court recognized that "a union may constitutionally spend funds for the expression of political views, on behalf of political candidates, or towards the advancement of other ideological causes not germane to its duties as collective bargaining representative." 431 U.S. at 235, 97 S. Ct. at 1800, 52 L. Ed. 2d at 284-85.
However, the Court held that "the Constitution requires . . . that such expenditures be financed from charges, dues, or assessments paid by employees who do not object to advancing those ideas and who are not coerced into doing so against their will." Id. at 235-36, 97 S. Ct. at 1800, 52 L. Ed. 2d at 285.
Despite holding that nonmembers of a union may not be compelled to contribute to expressive activities with which they disagree, the Court denied plaintiffs' application for a blanket injunction preventing the union from collecting dues used for political or ideological activities from any nonmember, thereby imposing the responsibility on each individual nonmember to communicate his or her objections to the union. Id. at 237-42, 97 S. Ct. at 1800-03, 52 L. Ed. 2d at 285-89.