Public Employees' freedom form compelled speech safeguards were set forth by the Supreme Court in 1986 in the Hudson decision [Teachers Local No. 1 v. Hudson, 475 U.S. 292 (1986)]. These safeguards include advance reduction; that is, if an employee objects to the use of his money for purposes other than collective bargaining, the union is supposed to collect from him only the amount that the union concedes goes towards collective bargaining costs, and not collect full dues and then later give the employee a rebate.
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