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Jason Manning and Frazier Satterly Secure Post-Janus Dues Deduction Win in the Seventh Circuit

Hodges Loizzi partners Jason Manning and Frazier Satterly recently secured a federal appellate victory for Moline-Coal Valley School District No. 40 in a case about union dues deductions following the Supreme Court’s Janus v. AFSCME ruling in 2018. Jason and Frazier initially prevailed on a motion for summary judgment in the District Court. The Seventh Circuit Court of Appeals affirmed the trial court’s decision.

The plaintiff in the case was a union member who signed an agreement authorizing the school district to deduct union dues from her paycheck. After she resigned from the union, union representatives reminded her that she was limited to a 15-day period to revoke her authorization, which would not be effective until months after her resignation.

The plaintiff claimed that the union and school district violated her First Amendment rights by continuing to deduct the dues without her consent, and she also challenged the constitutionality of a provision in the Illinois Educational Labor Relations Act (IELRA) that makes the bargaining unit the exclusive representative for all employees, whether or not the employees are union members.

Jason and Frazier successfully defended the school district’s actions before the District court on a motion for summary judgment and prevailed on appeal before the Seventh Circuit Court of Appeals. Jason argued the case on behalf of the school district before the Seventh Circuit Court of Appeals. Jason and Frazier worked closely with union counsel to defend the case in both the trial and appellate courts. The union also prevailed before the Seventh Circuit Court of Appeals.

The Seventh Circuit affirmed that the dues-deduction authorization window did not prevent workers from exercising free speech and free association. It also upheld the constitutionality of the exclusive-representative provision of the IELRA.

This victory was the lead story in a recent Chicago Daily Law Bulletin article (subscription required).

Jason Manning represents public and private schools, universities, companies, and individuals in all phases of litigation at the trial, appellate, and administrative levels, with a focus on complex school and commercial matters.

Frazier Satterly practices in all areas of school and municipal law. She works directly with clients in litigation to deliver inventive solutions to multifaceted legal issues.