Advocates for Labor and Progressive Institutions

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Seventh Circuit Affirms Enforcement Of Union Membership Agreement In Latest Post-Janus Decision

January 11, 2023

The United States Court of Appeals for the Seventh Circuit held that an Illinois teacher union was entitled to enforce the terms of a union membership agreement. In so holding, the court soundly rejected an argument that a teacher had a First Amendment right under the Supreme Court’s decision in Janus v. AFSCME, Council 31, 138 S. Ct. 2448 (2018), to avoid paying dues under that agreement.

The Court held that “Janus does not apply to union members,” such as the plaintiff, who voluntarily signed union membership agreements, but only to nonmembers. The case is Ariadna Ramon Baro v. Lake County Federation of Teachers Local 504, IFT-AFT/AFL-CIO, et al. (Case 22-1722). The decision is one of many in recent years that have rejected efforts by anti-union advocacy groups to invoke Janus as a basis to disrupt unions’ voluntary relationships with their own members.