AFSCME union officials told worker that formal membership and full dues payments are required just to keep her job

East Saint Louis, IL (February 11, 2026) – A mental health professional employed by University Correctional Healthcare Solutions has just filed a federal charge against the American Federation of State, County, and Municipal Employees (AFSCME) Council 31 union, maintaining that union officials are forcing her to join the union and pay full union dues – including dues for union politics.

The employee, J. Denise Bradley, is pursuing her case at the National Labor Relations Board (NLRB) with free legal aid from National Right to Work Foundation staff attorneys. The NLRB is the federal agency responsible for enforcing private sector labor law. Ms. Bradley works primarily at the Illinois Youth Center Pere Marquette in Grafton, IL.

Even though federal labor law permits union bosses in many states to force workers to pay money to a union to keep their jobs, the Supreme Court’s decision in NLRB v. General Motors forbids mandatory formal union membership. Additionally, the Foundation-won CWA v. Beck Supreme Court decision prohibits union officials from requiring workers who opt out of union membership to pay dues for the union’s “nonchargeable” expenses, which include political and ideological actions.

Illinois lacks Right to Work protections for its private sector workers, meaning union officials can enforce union contracts that require workers to pay money to the union or else be fired. However, this legal privilege is limited by Beck. In contrast, in Right to Work states like Illinois’ neighbors Wisconsin, Iowa, Indiana, and Kentucky, all union financial support is voluntary and the choice of each individual worker.

“My colleagues and I are very proud of the services we provide, as challenging as our jobs are. The last thing I need is AFSCME union officials threatening my livelihood because I refuse to support their regime inside the workplace and their political agenda outside the workplace,” commented Bradley. “No worker in any profession deserves to be bullied into funding a union they oppose, especially if they feel that the union isn’t doing anything to improve their work.”

Council 31 is notably the same AFSCME affiliate that Foundation attorneys faced in the 2018 Janus v. AFSCME Supreme Court decision. In Janus, the Supreme Court issued a landmark ruling establishing that public sector employees have a First Amendment right to refrain from paying dues to union officials. While Bradley works for a private contractor and is not under the purview of Janus, federal law still protects her from being forced to pay full dues or authorize automatic deduction of union dues for AFSCME Council 31.

AFSCME Union Officials Ignore Supreme Court Precedent, Use Unlawful Dues Forms

According to Bradley’s charge, AFSCME union officials told her and her coworkers that “it was a condition of employment to: (1) be a member of the Union; (2) pay full Union dues and/or (3) sign the Union’s unlawful dual-purpose membership and dues deduction authorization form.” Federal law prohibits the use of “dual-purpose” union membership forms, which confusingly demand that workers assent to both membership and direct paycheck deduction of union dues with only one signature.

In late 2025, Bradley attempted to exercise her right to refrain from union membership and her right to pay a reduced amount of union dues as per Beck. AFSCME union officials sent correspondence to Bradley rejecting her attempts to exercise her right under federal law to refrain from membership. Those communications also stated “the Union [does] not permit employees to pay a reduced fee.”

“Solely to preserve her employment, [Bradley] involuntarily signed the Union’s unlawful dual-purpose membership and dues deduction authorization form ‘under protest,’” the charges read. Bradley’s charges finally report that the union has never made any attempt to respect her rights under Beck and that full union dues are now flowing from her paycheck to AFSCME Council 31.

“AFSCME Council 31 union officials are just as intent on attacking workers’ free association rights as they were when Janus was being litigated,” commented National Right to Work Foundation President Mark Mix. “Instead of trying to win the support of Ms. Bradley and her coworkers voluntarily, they are ignoring federal laws to fund union political and ideological activities.

“Unions that disrespect employees like this don’t deserve a cent of employees’ hard-earned pay, which is why all American workers deserve the Right to Work freedom to choose for themselves whether or not to fund a union,” Mix added.

The National Right to Work Legal Defense Foundation is a nonprofit, charitable organization providing free legal aid to employees whose human or civil rights have been violated by compulsory unionism abuses. The Foundation, which can be contacted toll-free at 1-800-336-3600, assists thousands of employees in about 200 cases nationwide per year.