The court held that, under Hudson, the information provided was inadequate custom name cleveland indians baseball shirt to assure objectors that the expenditures cited had been independently verified.
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for 14 of the NLRA expressly preserves the authority of States to outlaw union-security agreements. Thus, petitioners’ argument runs, custom name cleveland indians baseball shirt the federal pre-emption essential to Hanson’s finding of governmental action is missing in the NLRA context, and we therefore need not strain to avoid the plain meaning of 8 as we did with 2, Eleventh. The Lehnert Court also based its holding on the fact that “worker and union cannot be said to speak with one voice.”53 But an objector’s mere disagreement with a union’s decision to pursue its representational objectives via lobbying activity surely does not render the related expenses nonchargeable. Given the absence here of the First Amendment concerns that dominate in the public sector, an objection to the union engaging in
lobbying is no different from disagreeing with the union over any strategic representational action, e.g., filing a lawsuit or taking a grievance to arbitration. The fact that the activity occurs within the political sphere does not change our core analysis. So long as lobbying is used to pursue goals that are germane to collective bargaining, contract administration, or grievance adjustment, it is chargeable to objectors. The Ninth Circuit, in Cummings v. Connell, 316 F.3d 886 (9th Cir. 2003), makes explicit what seems implicit in the Board’s decisions. The court held that a public sector union’s disclosure to objectors was insufficient because it did not include an independent verification that an audit had been performed. There, the union’s report provided to objectors broke down its annual expenditures into chargeable and nonchargeable categories. … As here, the union informed objectors that its figures were taken from an independent audit that had been prepared by a certified public accounting firm.
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