While each of the three major Supreme Court cases deals with a different segment of the
workforce (Lehnert with the rights of public employees under the Constitution, Ellis
with railway and airline employees under the RLA, and Beck with the rights of most
other employees under the NLRA), the principles behind employee dues protections are
essentially the same. The legal theories supporting these cases vary slightly, and the
procedural requirements are different, but the underlying principle is that union
dissenters cannot be compelled to contribute monetary support to those activities which
are not germane to the unions function within the workplace.