The Constitution’s guarantee of free association supports the notion that employees should be able to band together to advance a common interest. But this same guarantee should also allow an individual to opt out of such banding.[185] Such voluntary unionism would provide additional flexibility in school management and give a voice to those who do not share the positions taken by a union.

Twenty-two states have passed right-to-work laws for the private sector, which at least forbid forced unionism or forced agency. [186] Until such time as Michigan joins those states in some type of voluntary system, only skilled collective bargaining by school board members will keep union power in check. Unfortunately, unions are able to use that power in a manner potentially disadvantageous to the taxpayers and the employees who are forced to yield to union-mandated employment.