In Allee v. Medrano, 416 U.S. 802 (1974), the United Farm Workers brought suit against state officials in Texas alleging that they had conspired to deprive the union and others of their First Amendment rights. Id. at 804-05. The Court explained that the union was entitled to pursue its action: In this case the union has standing as a named plaintiff to raise any of the claims that a member of the union would have standing to raise . . . . It has been implicitly recognized that protected First Amendment rights flow to unions as well as to their members and organizers. If, as alleged by the union in its complaint, its members were subject to unlawful arrests and intimidation for engaging in union organizational activity protected by the First Amendment, the unions capacity to communicate is unlawfully impeded, since the union can act only through its members. The union then has standing to complain of the arrests and intimidation and bring this action. (Id. at 819 n.13. (