''Harris v. Quinn'', 573 U.S. 616 (2014), is a
US labor law
United States labor law sets the rights and duties for employees, labor unions, and employers in the US. Labor law's basic aim is to remedy the " inequality of bargaining power" between employees and employers, especially employers "organized in ...
case of the
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...
regarding provisions of
Illinois
Illinois ( ) is a U.S. state, state in the Midwestern United States, Midwestern United States. It borders on Lake Michigan to its northeast, the Mississippi River to its west, and the Wabash River, Wabash and Ohio River, Ohio rivers to its ...
state law that allowed a
union security agreement
Union commonly refers to:
* Trade union, an organization of workers
* Union (set theory), in mathematics, a fundamental operation on sets
Union may also refer to:
Arts and entertainment Music
* Union (band), an American rock group
** ''Unio ...
. Since the
Taft-Hartley Act of 1947 prohibited the
closed shop
A pre-entry closed shop (or simply closed shop) is a form of union security agreement under which the employer agrees to hire union members only, and employees must remain members of the union at all times to remain employed. This is different fr ...
, states could still choose whether to allow unions to collect fees from non-union members since the collective agreements with the employer would still benefit non-union members. The Court decided 5–4 that Illinois's Public Labor Relations Act, which permitted the union security agreements, violated the
First Amendment
First most commonly refers to:
* First, the ordinal form of the number 1
First or 1st may also refer to:
Acronyms
* Faint Images of the Radio Sky at Twenty-Centimeters, an astronomical survey carried out by the Very Large Array
* Far Infrared a ...
. A similar case was decided by the Court in 2018, ''
Janus v AFSCME'', overturning the Court's unanimous decision in ''
Abood v. Detroit Board of Education
''Abood v. Detroit Board of Education'', 431 U.S. 209 (1977), was a US labor law case where the United States Supreme Court upheld the maintaining of a union shop in a public workplace. Public school teachers in Detroit had sought to overturn t ...
'' (1977) which the appeals court had upheld in ''Harris''.
Facts
The
National Right to Work Legal Defense Foundation
The National Right to Work Legal Defense Foundation, established in 1968, is a nonprofit organization that seeks to advance Right-to-work law, right-to-work laws in the United States.
History
National Right to Work Legal Defense Foundation (NR ...
argued a claim against the Illinois's Public Labor Relations Act, on the ground that it violated the First Amendment. It allowed
labor unions
A trade union (British English) or labor union (American English), often simply referred to as a union, is an organization of workers whose purpose is to maintain or improve the conditions of their employment, such as attaining better wages ...
to collect fees for the union from non-union members since they would still receive the services of improved pay and conditions made through
collective bargaining
Collective bargaining is a process of negotiation between employers and a group of employees aimed at agreements to regulate working salaries, working conditions, benefits, and other aspects of workers' compensation and labour rights, rights for ...
. Staff worked for Illinois's Home Services Program and were paid by federal
Medicaid
Medicaid is a government program in the United States that provides health insurance for adults and children with limited income and resources. The program is partially funded and primarily managed by U.S. state, state governments, which also h ...
funding to work as a "personal assistant" to people who needed care. Both the patient receiving care and the state (as confirmed by executive order) were regarded as the employer. The trade union was
SEIU Healthcare Illinois & Indiana, which bargained with the state, after it was awarded exclusive representation of the caregivers following a card check election in 2003. The election was made possible by an executive order by then-Governor
Rod Blagojevich
Rod R. Blagojevich ( ; born December 10, 1956), often referred to by his nickname "Blago", is an American politician who served as the 40th governor of Illinois from 2003 to 2009. A member of the Democratic Party, Blagojevich previously worked ...
, who had been heavily supported by SEIU in his 2002 election. The order reversed a 1985 ruling by a state labor board that said the workers were not state employees. While SEIU claimed to have signed cards representing majority support of the workers, the state has not been able to prove that it ever properly verified the vote.
Eight home health care workers objected to paying union security fees, and challenged the law on this ground. Pamela Harris was the lead petitioner in the case, who was paid by the state to care for her own son. She objected to being obligated to pay dues to the SEIU Healthcare Illinois & Indiana union even though she chose not to join the union.
The District court dismissed their claim, and the Seventh Circuit affirmed the decision, following ''Abood v. Detroit Board of Education''.
Judgment
The Court ruled that the workers could not be compelled to join the union since they were not fully-fledged state employees, as they are hired or fired by individual patients even if they are paid by Medicaid. The ruling did not invalidate compulsory union membership for the larger population of public employees, but Justice
Samuel Alito
Samuel Anthony Alito Jr. ( ; born April 1, 1950) is an American jurist who serves as an Associate Justice of the Supreme Court of the United States, associate justice of the Supreme Court of the United States. He was Samuel Alito Supreme Court ...
's majority opinion argued that ''Abood v. Detroit Board of Education'' was erroneously decided.
Justice
Elena Kagan
Elena Kagan ( ; born April 28, 1960) is an American lawyer who serves as an Associate Justice of the Supreme Court of the United States, associate justice of the Supreme Court of the United States. She was Elena Kagan Supreme Court nomination ...
wrote the dissenting opinion, joined by Ginsburg, Breyer, and Sotomayor, arguing that the principle in the ''Abood'' ruling should have been used in the case.
Significance
The majority's opinion in ''Harris v. Quinn'' was largely condemned by labor unions, worker rights organizations , and the
Democratic Party for overturning established precedent since the
Taft-Hartley Act of 1947.
See also
*
*
References
External links
*
{{Portal bar, Freedom of speech, Illinois, Law, Organized labour, United States
2014 in United States case law
United States Supreme Court cases
United States Supreme Court cases of the Roberts Court
United States Free Speech Clause case law
United States public employment case law
Service Employees International Union litigation
United States trade union case law
2014 in labor relations