Knox v. Service Employees International Union, Local 1000, 132 S. Ct. 2277

California public-sector agency shop allows compulsory dues for chargeable expenses; nonmembers may be charged but cannot fund nonchargeable political/ideological activities.
SEIU Local 1000 issued a midyear Political Fight-Back Fund special assessment (1.25% with no cap) to defeat Prop. 75/76 and to influence 2006 elections.
Nonmembers objected or did not object to the special assessment; class comprised about 28,000 nonmembers.
District Court found the special assessment impermissible for directing funds to political purposes; Ninth Circuit reversed, applying Hudson in a broad balancing framework.
After certiorari, SEIU offered refunds, sparking mootness questions, but the Court held a live controversy remained regarding the adequacy of the refund notice, so the merits were reached.
Majority remanded for proceedings consistent with holding that a fresh Hudson notice and affirmative consent are required for special assessments used for political purposes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fresh Hudson notice required for midyear political assessment	Knox argued no new Hudson notice was needed	SEIU urged existing Hudson framework suffices	Fresh Hudson notice required; affirmative consent needed
Opt-out vs opt-in regime for such assessments	Petitioners favored opt-out (no new opt-in); relied on Hudson lineage	Majority adopts opt-in requirement for special assessments	Opt-in requirement applies to special assessments for political purposes

Abood v. Detroit Bd. of Ed., 431 U.S. 209 (1977) (nonmembers may not be forced to fund private speech unrelated to bargaining)
Hudson v. Teachers Union, 475 U.S. 292 (1986) (procedures must be narrowly tailored to minimize First Amendment infringement; have opportunity to challenge)
Davenport v. Washington Ed. Assn., 551 U.S. 177 (2007) (unions have no entitlement to nonmember fees; free-rider concerns exist)
Lehnert v. Ferris Faculty Assn., 500 U.S. 507 (1991) (nonchargeable activities require careful tailoring of fees; core principle of right not to subsidize misaligned speech)
Machinists v. Street, 367 U.S. 740 (1961) (dissent not presumed; opt-out context discussed in earlier dicta)
United Foods, Inc. v. Dept. of Agriculture, 533 U.S. 405 (2001) (compulsory subsidies require a comprehensive scheme and a necessary incident to the regulatory purpose)
New York State Bd. of Elections v. Lopez Torres, 552 U.S. 196 (2008) (open marketplace of ideas; government may not curb discourse)
Roberts v. United States Jaycees, 468 U.S. 609 (1984) (freedom of association includes freedom not to associate)