Hill v. Service Employees International Union et al.

Dist. Ct. did not err in dismissing for failure to state valid claim plaintiffs-home health care providers’ section 1983 action challenging on 1^st Amendment grounds certain provisions of Ill. Public Labor Relations Act that allowed single union (i.e., SEIU) to negotiate pay rates, hours and other conditions of employment for plaintiffs under circumstances where plaintiffs were under no obligation to join SEIU, and where plaintiffs were free to present their own grievances to State and associate with whomever they choose without retaliation from SEIU. While plaintiffs argued that instant statute improperly forced them into agency-like association with SEIU, Ct. rejected plaintiff’s claim that mandatory association with SEIU was subject to exacting scrutiny, especially where plaintiffs were free to join their own groups and to oppose SEIU. Moreover, instant statute satisfied rational-basis scrutiny, where Ill. has legitimate interest in negotiating with only one majority-elected exclusive bargaining representative when deciding what employment terms to offer plaintiffs.