In 1988, the Supreme Court, in Communications Workers of America v. Beck (hereinafter referred to as Beck ), ruled against organized labor and held that non-union employees could not be required to pay full union dues if some of those funds were to be used for activities unrelated to collective bargaining. Under § 8(a)(3) of the National Labor Relations Act (NLRA), a labor union and an employer can enter into a contractual agreement requiring all employees in the bargaining unit to pay union dues as a condition of employment no matter whether such employees became union members or not. The Supreme Court in Beck concluded that § 8(a)(3) of the NLRA (1) does not permit a labor union to expend funds on non-related union activities, such as lobbying and political activities, when dues-paying non-member employees object and (2) authorizes only those dues and fees necessary to the duties relating to labor-management relations. In 1991 the Supreme Court in Lehnert v. Ferris Faculty Association , expanded the scope of the Beck holdings to include public sector employees so that such employees may not be compelled to subsidize political or ideological activities of public employee unions. During the 1992 presidential election year, on April 13, 1992, President George Bush issued Executive Order 12800 requiring federal contractors to post notices informing employees of their rights under the Beck decision. It required notification to federal contractor non-union employees that their union dues may not be used to support political activities that they oppose. It also required the Secretary of Labor to issue rules providing for financial disclosure and reporting requirements for labor unions in order to provide enforcement of the Beck holdings. However, when President Bill Clinton took office, he repealed former President Bush's Executive Order by issuing Executive Order 12836 on February 1, 1993, which revoked certain executive orders concerning federal contracting. Prior to the Beck and Lehnert decisions, the Supreme Court regularly revisited this issue in a line of decisions which held that labor unions cannot use dissenting non-union employees' dues for political and ideological activities outside the scope of the activities related to collective bargaining. Such cases include: (1) International Association of Machinists v. Street , 367 U.S. 740 (1961); (2) Railway Clerks v. Allen , 373 U.S. 113 (1963); (3) Abood v. District Board of Education, 431 U.S. 209 (1977); (4) Ellis v. Brotherhood of Railway Clerks, 466 U.S. 435 (1984); and (5) Chicago Teachers Union v. Hudson, 475 U.S. 292 (1986). These cases will be discussed in more detail in part four of this report. Although this report will not discuss the case in more detail since it does not concern labor unions, note that in Keller v. State Bar of California , 496 U.S. 1 (1990), the Supreme Court held that an integrated state Bar, which by statute is the regulatory body for the legal profession in a state and requires the payment of mandatory dues by its members, is analogous to a union. Therefore, according to the Court, using mandatory dues to fund political and ideological activities, where such expenditures are not necessarily and reasonably incurred for the purpose of regulating the legal profession or improving the quality of the legal services available to the people of the State, the Bar violated the integrated Bar members' First Amendment rights. Generally, political activities by labor unions in federal elections are prohibited. First, the Labor Management Relations Act of 1947 prohibited labor union contributions to federal election campaigns. Later, the Federal Election Campaign Act of 1971, as amended, (FECA), generally continued this broad prohibition of labor union activities and funds in federal elections. However, the FECA provided for three broad exemptions to this general prohibition of labor union political activities in federal elections: (1) communications by a labor organization directed at its members or their families on any subject: (2) non-partisan voter registration and get-out-the-vote activities by a labor organization which are directed to its members or their families: and (3) the establishment and administration of a political action committee or separate segregated fund (commonly known as a PAC) for the purpose of the solicitation of contributions to such fund for political purposes. Generally, any other type of political activity by labor unions in federal elections is prohibited under the FECA, and labor union contributions and expenditures concerning federal elections outside these exceptions are prohibited. Various advisory opinions of the Federal Election Commission (FEC) have further clarified the proper roles of labor unions in federal elections. For example, according to the FEC: a teacher's union could pay for the expenses of interns working in a Member of Congress' mobile office as long as their activities were non-political and exclusively related to the performance of the Member's official duties; a labor union could circumvent political contribution requirements if it bought voter poll results from a candidate's campaign committee; a labor organization could not pay for travel and living expenses of its members who were serving as delegates to a national nominating convention; funds received by a labor PAC for the sale of membership lists would be treated as a contribution to the PAC; a labor union's PAC funds could be used to pay the expenses of lobbying activities conducted by labor union officials; a labor union's contributions to state and local candidates should specify that such funds cannot be used for federal candidates; and a labor union PAC can solicit employees of subsidiary corporations for contributions when the corporate PAC solicits such employees even though the employees are not union members and the subsidiary corporation is not subject to a union contract. FEC regulations also address the scope of a labor organization's participation in federal elections. Most notably, the regulations restrict those labor union communications directed to the general public and to union participation in voter registration and get-out-the vote-drives from containing express advocacy and prohibit coordination with any candidate or political party. The revised regulations permit a labor organization to make registration and get-out-the-vote (GOTV) communications to the general public if such communications: (1) do not expressly advocate the election or defeat of a clearly identified candidate or candidates of a clearly identified political party or (2) are not prepared or distributed with the coordination of a candidate or political party (will subsequently be referred to as "coordinated" or "coordination"). A labor union may also distribute to the general public, official registration and voting information and forms and absentee ballots (if permitted by applicable State law) provided that such distributions do not contain express advocacy and are not coordinated. A labor organization may donate funds to State or local government agencies to help defray the costs of printing and distributing these materials. Moreover, a labor organization may also prepare and distribute to the general public the voting records of Members of Congress and voter guides, provided that the these materials do not contain express advocacy and that there was no coordination involved. FEC regulations also permit a labor organization to support or conduct voter registration or GOTV drives aimed both at employees outside its restricted class and the general public, provided that: (1) the labor organization does not expressly advocate the election or defeat of a clearly identified candidate, or candidates of a clearly identified political party; (2) the labor organization does not coordinate with any candidate or political party; (3) the services are not primarily directed at individuals favored by the labor organization; (4) the services are made without regard to the voter's political preference; (5) the workers conducting such services are not paid only to register or transport voters supporting one or more particular candidates or political party; and (6) at the time these services are provided, the labor organization notifies, in writing, those receiving information or assistance regarding registration or voting of the availability of these services without regard to a potential voter's political preference. Finally, a labor organization may donate funds to qualified nonprofit organizations to stage candidate debates. Various federal court decisions have determined the legality of certain types of labor union activities involving federal elections. For example, in the 1957 decision United States v. United Automobile Workers, the Supreme Court held that labor union expenditures, in connection with a federal election, would be prohibited to the extent that such activity amounted to electioneering for a particular candidate or political party. The Court asserted that the legislative history of a provision of the Federal Corrupt Practices Act, prohibiting labor union contributions and expenditures in federal elections, would disallow the expenditure of union dues to pay for commercial broadcasts that are designed to urge the public to elect a certain candidate or political party. In United States v. Boyle , in 1973, the United States Court of Appeals for the District of Columbia Circuit, in affirming the conviction of a labor union president for consenting to unlawful contributions to federal candidates, held that there are compelling governmental reasons for justifying the federal prohibition against labor union contributions and expenditures in federal elections despite First Amendment free speech and association rights of the labor union. The Court of Appeals in Boyle concluded that for a labor union disbursement to be illegal under federal law, it must be shown that the labor organization: (1) made a contribution or an expenditure, (2) in connection with a federal election, and (3) for the purpose of active electioneering. In a 1972 Supreme Court decision in Pipefitters v. United States , reversing certain convictions of labor union officers concerning the use of a political fund, the Court concluded that a legitimate labor union political fund must be separate from the labor union in that there must be a strict segregation of the political fund's monies from the union's dues and assessments. The Court noted that, while former 18 U.S.C.