In the fall 2008 term, the U.S. Supreme Court will hear argument in Locke v. Karass, a case of more potential significance than suggested by the narrow question presented: whether, consistent with the First Amendment, the State may compel non-member employees to fund litigation by the affi liate of a union certifi ed as their exclusive bargaining agent. Certiorari was granted to resolve a circuit split over whether such “extra-unit” litigation expenses are “chargeable” to dissenting non-members, but Locke presents a possible opportunity for the Court to revisit the prevailing constitutional standard for determining when public sector unions may compel fi nancial support for their activities from non-members....