In Abood v. Detroit Board of Education, 431 U.S. 209 (1977), a decision issued a year after the effective date of Educational Employment Relations Act (EERA), the court considered Michigan statutory provisions essentially the same as the organizational security provisions of EERA and upheld the law only insofar as the fee charged was "used to finance expenditures by the Union for the purposes of collective bargaining, contract administration, and grievance adjustment." ( Id., at p. 225.) The Court considered the constitutionality of subsidies levied by work-related associations and whether the subsidies were germane to the purposes of the associations. In Abood, nonunion public school teachers challenged an agreement requiring them to pay a service fee equivalent to union dues. 431 U.S. at 211. The objecting teachers claimed that the union's use of the fees to engage in political speech violated their freedom of association as guaranteed by the First and Fourteenth Amendments to the United States Constitution. Id. at 213. The Supreme Court agreed. It held that requiring teachers to pay a service fee used "to contribute to political candidates and to express political views unrelated to its duties as exclusive bargaining representative" was unconstitutional. Id. at 234.