Beginning in the early 1960’s, the U.S. Supreme Court started to review First Amendment cases relating to union dues. Within this line of cases on union dues, a small subset relates to dues charged by teacher unions. In 1977, the Supreme Court heard Abood v. Detroit Board of Education. Washington Education Ass’n v. Washington (hereinafter “WEA”) is the most recent case to bring this topic before the U.S. Supreme Court through a challenge to the Washington “opt-in” law. Analysis in this paper begins by limiting analysis to the teacher union cases followed by an extension to other unions.