Drawing on private-sector employers’ experience and Congress’s legislative judgments, Abood properly recognized that the agency shop serves States’ strong interests in the orderly negotiation of terms and conditions of employment and resolution of employee grievances. A single representative is critical to avoid the confusion and burden of negotiating with multiple groups of workers with conflicting demands. When a union serves as exclusive representative, States have a vital interest in ensuring the fair allocation of the costs of that service to all employees.

Abood correctly held that the State’s interests as employer outweigh any interference with employees’ First Amendment rights. Abood fully accommodated non-members’ First Amendment interests by allowing non-members to opt out of contributing to unions’ political expenditures unrelated to collective bargaining. Agency-fee requirements impose no limits on employees’ right to speak against the union’s positions. Any compelled funding is ancillary to exclusive representation itself, the constitutionality of which is settled and unchallenged here.