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Yates v. Hillsboro Unified School District

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Yates v. Hillsboro Unified School District
Case number: 21-992
Status: Appealed to U.S. Supreme Court
Important dates
Filed: Dec. 5, 2019
District court decision:
Dec. 2, 2020
Appeals court decision:
Oct. 12, 2021
Supreme Court decision:
Pending
District court outcome
The district court dismissed the suit.
Appeals court outcome
The Ninth Circuit affirmed the district court's ruling.
Supreme Court outcome
Pending

This case is one of over a hundred public-sector union lawsuits Ballotpedia tracked following the U.S. Supreme Court's 2018 decision in Janus v. AFSCME. These pages were updated through February 2023 and may not reflect subsequent case developments. For more information about Ballotpedia's coverage of public-sector union policy in the United States, click here. Contact our team to suggest an update.

Yates v. Hillsboro Unified School District is pending before the U.S. Supreme Court. On October 12, 2021, the U.S. Court of Appeals for the Ninth Circuit affirmed the U.S. District Court for the District of Oregon's December 2020 dismissal of the suit. The plaintiffs filed their complaint on December 5, 2019, alleging that their union had unconstitutionally denied their resignation requests and that being compelled to pay dues without their consent violated the First Amendment.[1][2][3][4]

HIGHLIGHTS
  • The parties to the suit: The plaintiffs are Dori Yates, Claudia Strickland, and Tonya Sevilla. The defendants are Hillsboro Unified School District, Hillsboro Classified United AFT Local 4671, AFT Oregon, and American Federation of Teachers, AFL-CIO.
  • The issue: The plaintiffs challenged the constitutionality of their union’s maintenance of membership policy and said that being compelled to pay dues without their consent violated the First Amendment.
  • The presiding judges: Judge Marco A. Hernandez and Magistrate Judge Stacie Beckerman presided over the district court proceedings. A three-judge panel—Judges Margaret McKeown, William Fletcher, and Jay Bybee—presided over the case in the Ninth Circuit.
  • The outcome: This lawsuit is pending before the U.S. Supreme Court.

    • Procedural history

    The original plaintiffs were Dori Yates, Claudia Strickland, Tonya Sevilla, and Linda Newton. Newton voluntarily dismissed her case in March 2020. Yates, Strickland, and Sevilla are represented by attorneys from the Freedom Foundation. The defendants are Hillsboro Unified School District, Hillsboro Classified United AFT Local 4671, AFT Oregon, and American Federation of Teachers, AFL-CIO. They are represented by attorneys from Altshuler Berzon, LLP, and Hart Wagner LLP.

    The plaintiffs filed their lawsuit on December 5, 2019, in the United States District Court for the District of Oregon. The plaintiffs challenged the constitutionality of their union’s maintenance of membership policy and said that being compelled to pay dues without their consent violated the First Amendment.

    Below is a brief procedural history of the lawsuit:[1][2][3][4]

    • February 10, 2020: The defendants filed answers to the plaintiffs’ complaint.
    • April 24, 2020: The plaintiffs filed a motion for summary judgment.
    • May 29, 2020: The defendants filed a cross-motion for summary judgment.
    • October 19, 2020: Magistrate Judge Stacie Beckerman recommended that the defendants' motion for summary judgment be granted.
    • November 29, 2020: Judge Marco A. Hernandez adopted Beckerman's recommendation, granting the defendants' motion for summary judgment.
    • December 2, 2020: Hernandez dismissed the case with prejudice.
    • October 12, 2021: The Ninth Circuit affirmed the district court's dismissal of the case.

    For a list of available case documents, click here.

    Decision

    District court decision

    October 19, 2020, Magistrate Judge Stacie Beckerman recommended that the defendants' motion for summary judgment be granted:[5]

    “

    While the summary judgment motions were pending, the Ninth Circuit issued its opinion in Belgau v. Inslee ... affirming the district court’s entry of summary judgment in a nearly identical action alleging that deduction of post-resignation union dues from plaintiffs’ paychecks violated the First Amendment. ... The material facts here are not in dispute ... and summary judgment is appropriate where 'there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.' ... This case is indistinguishable from Belgau, which is not yet controlling pending issuance of a mandate, but is nevertheless persuasive here. Consistent with Belgau and the long line of unanimous district court opinions that have rejected Plaintiffs’ claims ... the Court finds that Defendants are entitled to judgment as a matter of law.[6]

    		”

    On November 29, 2020, Judge Marco A. Hernandez adopted Beckerman's recommendation, granting the defendants' motion for summary judgment.[7]

    Appellate court decision

    On October 12, 2021, a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit—Judges Margaret McKeown, William Fletcher, and Jay Bybee—affirmed the district court's dismissal of the suit.[3]

    Legal context

    Janus v. AFSCME (2018)

    See also: Janus v. AFSCME

    On June 27, 2018, the Supreme Court of the United States issued a 5-4 decision in Janus v. American Federation of State, County, and Municipal Employees (Janus v. AFSCME), ruling that public-sector unions cannot compel non-member employees to pay fees to cover the costs of non-political union activities.[8]

    This decision overturned precedent established in Abood v. Detroit Board of Education in 1977. In Abood, the high court held that it was not a violation of employees' free-speech and associational rights to require them to pay fees to support union activities from which they benefited (e.g., collective bargaining, contract administration, etc.). These fees were commonly referred to as agency fees or fair-share fees.[8]

    Justice Samuel Alito authored the opinion for the court majority in Janus, joined by Chief Justice John Roberts and Justices Anthony Kennedy, Clarence Thomas, and Neil Gorsuch. Alito wrote, "Abood was poorly reasoned. It has led to practical problems and abuse. It is inconsistent with other First Amendment cases and has been undermined by more recent decisions. Developments since Abood was handed down have shed new light on the issue of agency fees, and no reliance interests on the part of public-sector unions are sufficient to justify the perpetuation of the free speech violations that Abood has countenanced for the past 41 years. Abood is therefore overruled."[8]

    Related litigation

    To view a complete list of the public-sector labor lawsuits Ballotpedia tracked between 2019 and 2023, click here.

    Number of federal lawsuits by circuit

    Between 2019 and 2023, Ballotpedia tracked 191 federal lawsuits related to public-sector labor laws. The chart below depicts the number of suits per federal judicial circuit (i.e., the jurisdictions in which the suits originated).

    Public-sector labor lawsuits on Ballotpedia

    See also: Public-sector union policy in the United States, 2018-2023

    Click show to view a list of cases with links to our in-depth coverage.

    v • e
    Public-sector labor lawsuits
    Federal lawsuits

    Adams v. Teamsters Union Local 429 • Akers v. Maryland State Education Association • Aliser v. SEIU California • Allen v. Ohio Civil Service Employees Association • Allen v. Santa Clara County Correctional • Anderson v. SEIU Local 503 • Babb v. California Teachers Association • Baisley v. International Association of Machinists and Aerospace Workers • Belgau v. Inslee • Bennett v. AFSCME • Bermudez v. SEIU Local 521 • Bierman v. Dayton • Boudreaux v. Louisiana State Bar • Boyle v. SEIU California • Brice v. California Faculty Association • California v. Azar • Campos v. Fresno Deputy Sheriff’s Association • Carey v. Inslee • Casanova v. IAM Local 701 • Chandavong et al. v. Fresno Deputy Sheriff's Association et al. • Cook v. Brown • Cooley v. California Statewide Law Enforcement Association • Crowe v. Oregon State Bar • Cruz v. Union Independiente Autentica de Empleados de la Autoridad de Acueductos y Alcantarillados • Danielson v. Inslee • Diamond v. Pennsylvania State Education Association • Doughty v. State Employees Association of New Hampshire, SEIU, Local 1984 • Durst v. OEA • Few v. United Teachers Los Angeles • File v. Hickey • Fischer v. Murphy • Fisk v. Inslee • Fizer v. Ohio Association of Public School Employees • Fleck v. Wetch • Grega v. Council of New Jersey State College Locals • Grossman v. Hawaii Government Employees Association • Gruber v. Oregon State Bar • Guppy v. City of Los Angeles • Halloran v. AFSCME Council 5 • Hamidi v. SEIU • Hannay v. Kent State • Hartnett v. Penn. State Education Association • Hendrickson v. AFSCME Council 18 • Hernandez v. AFSCME California • Hoekman v. Education Minnesota • Hough v. SEIU Local 521 • Imhoff v. California Teachers Association • Jackson v. Napolitano • James v. SEIU Local 688 • Janus v. AFSCME • Jarchow v. Wisconsin • Kabler v. United Food and Commercial Workers Union, Local 1776 Keystone State • Wenzig v. SEIU Local 668 • Kopie v. International Federation of Professional and Technical Employees • Kurk v. Los Rios Classified Employees Association • Lamberty et al. v. Connecticut State Police Union et al. • LaSpina v. SEIU Pennsylvania State Council • Lee v. Ohio Education Association • Leitch v. AFSCME • Littler v. Ohio Association of Public School Employees • Loescher v. Teamsters Local 320 • Lutter v. JNESO • Mandel v. SEIU Local 73 • Marsh v. AFSCME Local 3299 • Martin v. California Teachers Association • Masuo v. AFSCME AFL-CIO • Matthews v. United Teachers of Los Angeles • Mattos v. AFSCME Council 3 • Mayer v. Wallingford-Swathmore School District • McCain v. Ventura County Federation of College Teachers, AFT Local 1828 • McCollum v. NEA-Alaska • McCutcheon v. CWA Local 7076 • McDonald v. Firth • Mendez v. CTA • Miller v. Inslee • Misja v. PSEA • Molina v. SEIU Local 668 • Mooney v. Illinois Education Association • Nearman v. SEIU Local 503 • Neely v. AFSCME Council 13 • Nguyen v. Admin. and Residual Employees Union • Nichols v. Home Care Providers Union • O'Callaghan v. Drake • Ochoa v. Public Consulting Group • Ocol v. Chicago Teachers Union • Ogle v. Ohio Civil Service Employees Association, AFSCME, Local 11 • Oliver v. SEIU Local 668 • Pellegrino v. New York State United Teachers • Penning v. SEIU Local 1021 • Polk v. Yee • Popp v. ALPAI • Piekarski v. AFSCME Council 5 • Quirarte v. UDW AFSCME Local 3930 • Reisman v. Associated Faculties of the University of Maine • Rizzo-Rupon v. International Association of Machinists and Aerospace Workers, District Lodge 141 • Routh v. Inslee • Schaszberger v. AFSCME Council 13 • Schell v. Oklahoma Supreme Court Justices • Schumaker v. Inslee • Seager v. UTLA • Seidemann v. Professional Staff Congress • Smith v. AFSCME Council No. 8 • Smith v. New Jersey Education Association • Smith v. Bieker • Solomon v. AFSCME District Council 37 • Stroeder v. Service Employees International Union, Local 503 • Sweeney v. Raoul • Sweet v. California Association of Psychiatric Technicians • Taylor v. Heath • Thompson v. AFSCME Council 89, Local 4013 • Thompson v. Marietta Education Association • Thulen v. AFSCME • Uradnik v. Inter Faculty Org. • Utke v. University of Connecticut American Association of University Professors • Weyandt v. PSCOA • Wholean v. CSEA SEIU Local 2001 • Wilford v. National Education Association • Williams v. PSEA • Wolf v. University Professional & Technical Employees • Yates v. Hillsboro Unified School District • Yohn v. California Teachers Association

    See also

    External links

    Case documents

    Supreme Court

    Appeals court

    Trial court

    Footnotes

    1. ↑ 1.0 1.1 PacerMonitor, "Complaint," December 5, 2019
    2. ↑ 2.0 2.1 PacerMonitor, "Yates et al v. Hillsboro School District et al," accessed February 18, 2022
    3. ↑ 3.0 3.1 3.2 PacerMonitor, "Dori Yates, et al v. Hillsboro Unified School Dist., et al," accessed February 18, 2022
    4. ↑ 4.0 4.1 Supreme Court of the United States, "No. 21-992," accessed February 18, 2022
    5. ↑ PacerMonitor, "Findings and Recommendation," October 19, 2020
    6. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ PacerMonitor, "Order," November 29, 2020
    8. ↑ 8.0 8.1 8.2 Supreme Court of the United States, Janus v. American Federation of State, County, and Municipal Employees, Council 31, et al., June 27, 2018
    v • e
    Public-sector union policy in the United States
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