The U.S. Supreme Court case National Labor Relations Board v. Local 825, International Union of Operating Engineers, AFL-CIO in 1970 revolved around the issue of whether a labor union could require non-union employees to pay for services provided by the union under a collective bargaining agreement. The court ruled that it was unlawful for unions to demand payment from non-union members for representation in grievance procedures unless there was an explicit provision within their contract allowing them to do so. This decision upheld the principle that individuals cannot be compelled into financial support of a group or cause without their consent and reinforced protections against forced association with labor unions.

In the dissenting opinion for the case of NATIONAL LABOR RELATIONS BOARD v. LOCAL 825, INTERNATIONAL UNION OF OPERATING ENGINEERS, AFL-CIO, Justice Black disagreed with the majority's decision to uphold a National Labor Relations Board (NLRB) order that found Local 825 in violation of federal labor law. The union had refused to refer non-union workers for employment opportunities unless they paid union dues and initiation fees. Justice Black argued that this was not an unfair labor practice because it did not involve coercion or restraint on employees' rights under Section 7 of the National Labor Relations Act (NLRA). He contended that unions should be allowed to charge non-members fees as compensation for services provided by them such as collective bargaining and job referrals. Furthermore, he criticized NLRB’s interpretation of NLRA provisions which led them to conclude these charges were illegal restraints on employee rights. In his view, Congress intended those provisions only against coercive practices like threats or violence but didn’t mean to prevent unions from charging legitimate service fees.