Christina Littler v. Ohio Ass'n of Pub. Sch. Emp.

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 28, 2022
Docket20-3795
StatusUnpublished

This text of Christina Littler v. Ohio Ass'n of Pub. Sch. Emp. (Christina Littler v. Ohio Ass'n of Pub. Sch. Emp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christina Littler v. Ohio Ass'n of Pub. Sch. Emp., (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0133n.06

No. 20-3795

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

) FILED Mar 28, 2022 CHRISTINA LITTLER, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE SOUTHERN OHIO ASSOCIATION OF PUBLIC SCHOOL ) DISTRICT OF OHIO EMPLOYEES, ) ) Defendant-Appellee. ) )

Before: WHITE, NALBANDIAN, and READLER, Circuit Judges.

HELENE N. WHITE, Circuit Judge. Christina Littler joined the Ohio Association of

Public School Employees (OAPSE) in 2015. Her membership application provided that the union

would be her sole representative in employment negotiations and authorized the union to collect

monthly dues from her paycheck. After the Supreme Court issued its opinion in Janus v. American

Federation of State, County, & Municipal Employees, Council 31, 138 S. Ct. 2448 (2018), holding

that public sector unions may not collect fees from nonmembers without their express consent,

Littler attempted to resign her union membership by email. OAPSE informed Littler that a

handwritten signature was required to effect a valid withdrawal under the terms of the membership

agreement, but Littler declined to provide one. OAPSE did not remove Littler from its list of

members subject to paycheck dues deduction, and the district deducted the dues when the dues-

collection period began in November 2018. No. 20-3795, Littler v. Ohio Association of Public School Employees

Littler brought this action, alleging that OAPSE failed to honor her constitutional right to

freedom of speech when it continued to deduct dues from her paycheck after she asked to

withdraw. OAPSE responded that it was entitled to collect the dues according to Littler’s signed

membership agreement because Littler never validly withdrew her authorization. The district court

granted summary judgment in favor of OAPSE and this appeal followed. We reverse and remand

to the district court for further proceedings consistent with this opinion.

I.

A.

OAPSE is a public-sector union that represents over 30,000 employees in Ohio, including

a bargaining unit of employees of the South-Western City School District (the “District”). Prior

to the Supreme Court’s decision in Janus, most employees in OAPSE-represented bargaining

units, including the South-Western City Schools unit, had a choice between joining the union as

dues-paying members or remaining non-members, but paying a fair-share fee to defray the cost of

OAPSE’s collective-bargaining and representational activities. After Janus, OAPSE ceased

collecting fair-share fees from non-members.

Littler became a substitute bus driver for the District in 2011. Littler did not join OAPSE

at that time because she did not believe substitute bus drivers could be union members. Because

she was not a union member, Littler paid reduced union fees, also known as fair-share fees, as

required at the time under the Collective Bargaining Agreement (CBA). When Littler became a

full-time bus driver, she joined OAPSE.1 On January 16, 2015, Littler signed an OAPSE

membership application card. Littler does not recall the circumstances under which she signed the

1 Littler’s testimony on her reason for joining OAPSE was inconsistent. At her deposition, she claimed she believed that full-time bus drivers were required to be union members. She also attested that she chose to join and remain a member of the union, if “reluctantly,” because the cost of full union membership, as compared to the cost of the fair-share fee, was not worth the loss of her vote and influence in union matters. R. 52, PID 1905.

-2- No. 20-3795, Littler v. Ohio Association of Public School Employees

membership application but does remember that she did not read the membership application when

she signed it. The membership application stated, in relevant part:

I further authorize and direct the Employer to deduct OAPSE State dues and Local dues as set forth herein or as increased from my salary or wages and remit the same to the OAPSE State Treasurer. This authorization shall remain in effect during my employment unless withdrawn by me in the manner provided in the Collective Bargaining Agreement between the Employer and OAPSE or, where there is no provision for withdrawal in the Agreement, only during a 10 day period from August 22 through August 31. I agree that any withdrawal of dues deduction authorization shall be in writing, executed and delivered during the revocation period by written notice served upon the Chief Fiscal Officer of the Employer and the OAPSE State Treasurer. I further agree that dues deduction may not be revoked at any other time or in any other manner except as provided herein.

R. 37-1, PID 1016.2 OAPSE transmitted Littler’s signed membership application to the South-

Western City School District, which then deducted membership dues from her paycheck and

remitted them to OAPSE in accordance with the CBA.

Under the CBA between OAPSE and the District, OAPSE is required to submit a list of all

OAPSE members and the appropriate payroll deduction for each member by October 20 each

calendar year. The list must be accompanied by signed membership application cards for all new

members, indicating authorization of payroll deduction. Where a union member is listed, but no

application card is on file with the District treasurer, the Board of Education treats the individual

as a non-member for payroll purposes. Dues are deducted over an eight-month period from

November through June 30.

On June 27, 2018, the Supreme Court held that the imposition of mandatory fair-share fees

on non-union members by public-sector unions is unconstitutional. See Janus, 138 S. Ct. at 2460.

In response, OAPSE stopped collecting fair-share fees from non-members.

2 The CBA contains no provisions for withdrawal, so the parties agree that the withdrawal procedures outlined in the membership application are applicable.

-3- No. 20-3795, Littler v. Ohio Association of Public School Employees

On August 22, 2018, Littler sent an email (the “August email”) to Gary Martin, the Director

of Membership Services for OAPSE, and Hugh Garside, the Treasurer and Chief Fiscal Officer

for the District, stating that she was “immediately withdrawing [her] union membership.” R. 52-

1, PID 1910. Over the next week, Chad Caldwell, an OAPSE representative, called Littler and left

several voicemails asking her to contact him and advising that her email attempting to withdraw

from the union would not be accepted because it did not contain a handwritten signature. 3 On

August 28, 2018, Littler sent another email to Martin and Garside requesting that Caldwell stop

calling her. Littler took no other action to effectuate her withdrawal. OAPSE determined that

Littler’s August email did not constitute a valid withdrawal because it lacked a handwritten

signature and notified the District that it should continue to deduct dues from Littler’s paycheck.

Dues continued to be deducted from Littler’s paycheck when the 2018–2019 dues-

deduction period began in November 2018. In February 2019, OAPSE changed its policy for

validating member withdrawals and determined that it would begin accepting emailed withdrawal

requests that lacked a handwritten signature, provided it was clear that the email originated with

the member. OAPSE also decided to retroactively honor requests made during the 2018

withdrawal period that complied with the revised policy.

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