## Facts

- Railroads and unions executed a union-shop agreement under § 2, Eleventh of the Railway Labor Act requiring employees, as a condition of employment, to join the union and pay initiation fees, assessments, and dues.
- Several employees objected that a substantial portion of their compelled payments was used to support political candidates and to advance political and economic views they opposed.
- A Georgia trial court found the allegations proved, held the agreement unconstitutional as applied, enjoined enforcement of the union-shop agreement, and awarded certain employees monetary relief.
- The Supreme Court of Georgia affirmed the trial court’s judgment.
- The unions appealed to the U.S. Supreme Court.

## Issues

1. Whether § 2, Eleventh of the Railway Labor Act authorizes a union, over an employee’s objection, to use compulsory dues for political causes and ideological activity unrelated to collective bargaining.
2. Whether compelled subsidization of political and ideological activity, if authorized, would violate dissenting employees’ First Amendment rights.

## Decision

- The U.S. Supreme Court reversed and remanded.
- The Court construed § 2, Eleventh to deny unions authority, over an employee’s objection, to spend compelled dues for political causes the employee opposes.
- The Court declined to decide the First Amendment question, relying on statutory interpretation to avoid unnecessary constitutional adjudication.
- The Court directed the lower courts to craft a narrower, more appropriate remedy than invalidating the union-shop arrangement as a whole.

## Legal Principles

- Under § 2, Eleventh, compelled financial support may be required to cover the costs of the union’s statutory duties as exclusive bargaining representative, including negotiating and administering collective agreements and adjusting and settling disputes.
- Section 2, Eleventh does not permit a union, over an employee’s objection, to use exacted funds to support political candidates, political causes, or ideological advocacy unrelated to collective bargaining.
- Courts should, where fairly possible, interpret statutes to avoid deciding constitutional questions, particularly when narrower statutory grounds can resolve the dispute.
- Remedies should be tailored to the unlawful use of funds (e.g., limiting relief to the political-expenditure portion) rather than broadly prohibiting the union-shop arrangement that the statute permits.

## Conclusion

The Court held that the Railway Labor Act authorizes compulsory dues only to finance a union’s representational functions and does not allow unions to use objecting employees’ compelled payments for political or ideological causes the employees oppose; it reversed the state-court injunction and damages award and remanded for a narrower remedy.


Int’l Ass’n of Machinists v. Street, 367 U.S. 740 (1961)