Public employee unions, American politics, and the Catholic Church

Social doctrine and labor unions

In 1891, Pope Leo XIII wrote in Rerum Novarum that a worker’s wages should support the worker and his family. His understanding of marriage and family—which together form the nucleus of Christian justice and charity—is foundational to Catholic social doctrine.

The Catholic Church views the family as comprising a committed husband and wife, along with their children, with a widening familial responsibility to the extended family and the broader human community. Our sacrifices and service to others will require us to discern our responsibilities as employees and employers, as parents and children, as neighbors and strangers, throughout our lives.

The history of U.S. labor relations over the last 150 years has consistently reminded the public, academics, and cultural leaders of humanity’s need for Christian neighbor-love and the dangers of riches, honor, and pride. One can recall the 19th-century scourge of slavery as well as the 19th and early 20th-century robber barons and their monopolistic, industrial trusts. However, some labor union leaders and their members have also succumbed to the temptations of riches, honor, and pride. They and their supporters can become powerful, self-absorbed, and sinful with unlawful and immoral kickbacks, sweetheart contracts, manipulated union elections, and nepotism. The leaders and followers of any institution, including the Church and its adherents, have been and can become corrupt, or at the very least, selfish.

While labor unions and their religious supporters have historically organized for justice in the workplace, unions can also mistakenly domineer and demand in authoritarian ways. Even if they are free of unlawfulness, unions and other mediating social institutions can create a slippery slope of misguided cultural initiatives by promoting ideological, anti-Christian norms for society. This confusion includes the acceptance of divorce, the proliferation of pornography, the promotion of so-called “same-sex marriage”, the grooming of innocent children, the error of transgenderism, and attempts at normalizing abhorrent sexual practices.

Such thinking has led to a 20th-century diminishment of the commitment of marriage between a man and a woman, the foundation of the family in Catholic social doctrine. It is also an attack on any well-formed practicing Christian.

The labor movement helped win the 40-hour workweek and other benefits for union and non-union workers. Faith in God and religious practice motivated many unionists to remind the haves that the have-nots were also created in the image of God. The materialist Marxian worldview never played a significant role in American labor history, but religious faith and justice did.

In the United States, Mary “Mother” Jones (1837-1930), baptized, raised, married, and buried as a Catholic, animated and organized U.S. workers and their families. Another practicing Irish Catholic, Terence Powderly (1849-1924), made a significant contribution to organizing the 19th-century Knights of Labor. He convinced James Cardinal Gibbons of Baltimore and the Catholic hierarchy that the Knights were not a secretive anti-Catholic organization but supporters of struggling workers and their families, oftentimes Catholics. Like the Church’s perspective, he favored workingmen’s associations, rather than anything like communism or radical labor syndicalism that would usurp private property ownership. As the Knight Grandmaster, he also discouraged labor strikes as a means to peace and prosperity for workers and their employers.

The Catholic Social Encyclicals

Rerum Novarum emphasized the right to property ownership and strongly advocated for its protection. Private property is not contrary to the social good when it serves the owners and others appropriately and reasonably—the poor care for the little they possess. Living in Jerusalem, as I do, one sees the Church protecting its institutional properties and historical rights, which serve others here and abroad. Like any reasonable and responsible individual or community, the Church protects and manages every gift from God to support others, Christian or not.

Leo XIII criticized both capitalism and socialism, and the workingmen’s associations he described and encouraged are not today’s politicized public sector unions. From a Marxist view of the world, he was not making a class option for the poor. However, he also believed the natural needs of God’s sons and daughters (e.g., shelter and food) were more essential than the “natural” workings of market-driven supply and demand. In more contemporary terms, he believed that an economy was made for the people, not the people for the economy.¹

The state could help protect workers’ rights, but Pope Leo XIII’s approach emphasized cooperation and harmony within the socio-economic order, rather than class warfare. Pius X followed the caution of Leo XIII. He did not see a classless society as possible and believed that cooperative, worker-owned businesses were too idealistic.² In Quadragesimo Anno (1931), Pius XI promoted a spirituality of justice in line with St. Thomas Aquinas’ understanding of general justice, again, the common good. Personal sins, such as greed, led to structural injustices and necessitated a communal response that involved some state intervention.

During the pontificate of Pius XI, President Franklin D. Roosevelt signed the National Labor Relations Act (NLRA), also known as the Wagner Act, in 1935. It granted private sector workers the state-supported right to join unions, bargain collectively with their employers, and engage in strike action if necessary. It became the “Magna Carta of the working man.”

Pius XII became more demanding of others when he argued that all people should have access to the benefits of God’s Creation. Private property is respected, but the haves should never neglect the needs of the have-nots. Throughout the 20th century, the Church’s social teaching evolved into a stronger call for economic justice, challenging the few who held excessive amounts of property in light of the significant needs of many others.³ In the encyclical Mater et Magistra (1961), John XXIII advocated for a more corporatist relationship among government, industry, and labor. Workers would have their associations, and governments could work with employers and employees to benefit society.⁴ Today, Scandinavian countries have arrangements with worker representatives on corporate boards and government participation in social welfare concerns that attempt to serve the entire population.

In Populorum Progressio (1967), Pope Paul VI acknowledged that a smaller percentage of the world’s population had amassed a larger percentage of total wealth, and the basic needs of the poor transcended property rights. This was a conservative statement, made to anyone of goodwill, emphasizing that the poor come before the amassing and holding of exponential amounts of wealth by a few. He was not advocating a unilateral appropriation of wealth rightly received in God’s providence, but speaking to the powerful and wealthy, middle class, and poor alike about the common good. Our Lord Jesus Christ comes to us in the poor; whatever we do to the least of our brothers, we do to him. For Paul VI, poverty can warrant reasonable and prudent structural changes to assist those in serious need.⁵

Pope John Paul II promoted worker solidarity as a positive trait for humanity. In Laborem Exercens (1981), he speaks of every person as a worker, prioritizing labor over capital. Jesus was a carpenter like his father; he, in a sense, divinized work for us. Life was about people and their well-being, not maximizing pleasure, manifested in riches, honor, and pride. By seeing every person as a worker, everyone becomes a worker, erasing any fixation on class divisions based on work. John Paul II, like earlier popes, did not offer a specific means to achieve socio-economic justice. He, however, correctly reminded the broader world that we are made in the image of God and need to live in a loving and caring way appropriate to God’s sons and daughters.⁶

In Centesimus Annus (1991), John Paul II sought to prevent people from viewing labor unions as class-based or identity-based organizations. He said the Church accepted labor unions in part because they represented the freedom to associate. His focus was on workers, citizens, and employers working together to promote the common good.⁷

Pope Benedict XVI was Cardinal Joseph Ratzinger, Prefect of the Congregation for the Doctrine of the Faith from 1981 to 2005. His office approved the Compendium of Catholic Social Doctrine. For this essay, my concern is the mistaken advocacy and promotion of homosexual causes from within the government itself by public sector union leaders and members. This attack from within becomes a politicization of their public service work, which negatively impacts both marriage and the family.

Pope Benedict XVI helped prepare and approve the Church’s position that the state can support marriage between a man and a woman or diminish it.

If, from the legal standpoint, marriage between a man and a woman were to be considered just one possible form of marriage, the concept of marriage would undergo a radical transformation, with grave detriment to the common good. By putting homosexual unions on a legal plane analogous to that of marriage and the family, the state acts arbitrarily and in contradiction with its duties. (The Compendium of Catholic Social Doctrine, para. 228).

Church teaching on labor, wealth, and community has always seen God, Creation, and the common good as supporting marriage between a man and a woman, their family, and their needs.

Government employee unions’ dismissal of voter sensibilities

Beginning in the late 19th century, nation-states began to legislate the right of workers to organize and collectively bargain for fair wages, benefits, and working conditions. Catholic social teaching recognized solidarity as a good, but never promoted selfishness or illicit gain based on collective power. Labor unions can play an important role in protecting workers and delivering high-quality services and products in both the public and private sectors.

The National Labor Relations Act protected the right to organize and collectively bargain over wages, benefits, and working conditions in the private sector. Public sector employees, however, had no labor organizing protections or collective bargaining rights except for civil service guidelines on selection, hiring, promotion, and workplace practices.

In 1962, by Executive Order 10988, President John F. Kennedy granted federal employees the right to collective association and bargaining. However, this right did not include the authority to bargain over wages and benefits or the right to strike. It was a recognition of employee representatives in the hope of encouraging like-minded civil servants to contribute to the government’s success. Politically, he was also beholden to labor for helping him win the presidency, as were most Democratic presidents since FDR. A federal task force also suggested that collective bargaining would improve employee relations, and Congressional legislation was in the works.⁸

On the one hand, it was a form of workplace democratization, encouraging administrators and employees to improve their work and enhance the government’s effectiveness. In other words, federal workers would have more intrinsic and extrinsic rewards. Federal employees would value their vocation in public service and benefit from good working conditions and cooperation. Kennedy intended to unite, not divide, managers, their subordinates, and the public they served.

On the other hand, it increased the political power of federal employees, making them less vulnerable to political appointees and potentially less responsive to the electorate and their duly elected political leaders. Unlike private sector employees, they can simultaneously influence public policy and its implementation within and outside the government, both as workers and as private citizens. Government employees, like business groups and private sector unions, have maintained powerful lobbying forces in state capitals and Washington, D.C.

President Richard Nixon’s Executive Order 11491 (1969) defined unfair labor practices more specifically and created the Federal Labor Relations Council. Although not as freely balanced as the NLRB, it provided binding arbitration in some cases. The Federal Service Impasses Panel helped resolve public sector bargaining impasses. Executive Order 11491 brought federal employees significantly closer to the protections afforded by the National Labor Relations Act. Although federal workers do not have the right to bargain over wages, benefits, job classifications, or strike to this day,⁹ these limitations are not necessarily true for state and municipal employees, as the rights vary widely by state.

Collective bargaining and labor relations are much more challenging in the public sector than in the private sector because the ultimate manager is the electorate, the voters. A private employer, subject to certain labor law limitations, can shut down operations, offshore work, or subcontract it. Public sector management, in many cases, cannot. This fact strengthens the public sector unions, which can go to the electorate, the legislative branch, or the administrative state (i.e., management/political appointees) to find allies. Over time, public sector unions will have a greater ability to influence management policy-making, hiring, and promotion decisions, as well as the delivery of services, than private sector unions. They can utilize their social and political capital to shape the understanding and will of an electorate.

Significant events occurred in public employee labor relations during the mid-20th century. At the national level, starting in New York City, the postal workers went on a wildcat strike in 1970, demanding higher wages and improved working conditions. Nixon called out the National Guard to ensure continued deliveries. With assurances to the strikers, the National Association of Letter Carriers negotiated a collective bargaining agreement that included wage negotiations but not the right to strike.¹⁰

In 1981, President Ronald Reagan fired over 12,000 striking air traffic controllers represented by the Professional Air Traffic Controllers Organization. After this national confrontation between Reagan and labor, the number of strikes across the United States decreased dramatically as Reagan’s quick use of military and retired air traffic controllers emboldened private employers to follow suit.¹¹

Under President Jimmy Carter, Congress passed Title VII of the Civil Service Reform Act. It established the Federal Labor Relations Authority (FLRA), which would no longer serve as a “management council” resolving unfair labor practice charges but as an “independent and bipartisan Authority.” While federal employees had no right to strike or bargain over wages and benefits, management and employee rights paralleled those of private sector employers in many respects. The FLRA included a General Counsel who protects the rights of both employees and management, subject to judicial rule, and supervises representation elections.¹²

The administrations of Presidents George H. W. Bush, Bill Clinton, George W. Bush, and Barack Obama were not notable for promoting new labor legislation in either the private or public sectors. They made political appointments, especially to the NLRB and federal courts, reflecting the historical pro-labor and pro-business tendencies of the Democratic and Republican parties, respectively. President George H. W. Bush also attempted but failed to limit the organizing of certain federal workers under the Homeland Security Act.¹³ Although labor union members helped Presidents Clinton and Barack Obama win their elections, neither of them made significant legislative initiatives to advance union organizing.¹⁴ The Obama administration failed to win passage of the Employee Free Choice Act, which would have facilitated union representation through simple card checks in the private sector, thereby significantly aiding union organizers by eliminating the need for workplace campaigns and secret ballot elections.

Until President Trump’s first term and now re-election, President Kennedy’s Executive Order 10988 remained the linchpin of federal labor relations, influencing all future administrations, with further adjustments, additions, and subtractions made depending on the political party in power.¹⁵

During his first term, Trump signed four Executive Orders (13836, 13837, 13839, and 13957) to reorganize the federal government’s collective bargaining duties through the “Interagency Labor Relations Working Group” and create more management oversight of the workers’ fulfillment of work responsibilities. In part, they would reorganize federal agencies, establish a one-year deadline for contract bargaining, provide online access to negotiated contracts, limit the use of official time for union activities, make the dismissal of federal employees for cause easier, and create “Schedule F” to facilitate the dismissal of federal employees with policy-making roles. Some members of Congress questioned the changes, and the federal labor unions contested them in court, as they are now contesting Trump’s second-term executive orders.

Then, U.S. District Court Judge Ketanji Brown Jackson rejected Trump’s Executive Orders 13836, 13837, and 13839, issuing an injunction to stop their implementation. The U.S. Court of Appeals for the District of Columbia overruled her decisions. At the beginning of his presidency, President Joe Biden quickly revoked Trump’s Executive Orders for Federal Workers, specifically 13836, 13837, 13839, and 13957.¹⁶

Woke activism at the service of LGBTQ ideology

Judge Ketanji Brown Jackson, now a Supreme Court Justice, refused to define “woman” at her confirmation hearings.¹⁷ Although at one point she implies that biology does have something of value to say about what a woman, or a man, is. Science is something that postmodern, nonbinary proponents want society to question, denying it even a modicum of intellectual respect and rejecting common sense. Yet postmodernists continually create categories, that is, self-defined identities (LGBTQ, etc.) to fit their predilections and subjective truths.

They allow no one to dispute their boundaryless categories, truth be damned. Public sector unions are deeply entangled in this deception, whereas American populist voters, including many union members, are rightfully not. Numerous political analysts and pollsters suggest that the Democratic Party and, by implication, the U.S. labor movement have lost the support of working people.¹⁸

In President Trump’s second term, he has signed 157 new executive orders, many of which are unrelated to federal labor relations. In the case of labor relations, he has continued his first-term efforts to downsize the federal workforce and end union protection for some positions. He reinstated Executive Order 13957, the “Schedule F” order, renaming some federal worker positions as “Schedule Policy/Career positions,” which will allow unilateral dismissal of employees who undermine:

…the policies and directives of their executive leadership. Principles of good administration, therefore, necessitate action to restore accountability to the career civil service, beginning with positions of a confidential, policy-determining, policy-making, or policy-advocating character.¹⁹

Trump’s supporters wanted an administration that would prevent woke public employees from rejecting or blocking their duly elected representatives from fulfilling their electoral mandate.

In 2025, Trump has now issued nearly 40 executive orders that address government administration and its workforce. One clear order that addresses the culture wars is “Executive Order: Ending Radical and Wasteful Government DEI Programs and Preferencing.” Trump and his supporters realize that federal unions and the culture war activists within those unions have become a fifth column for wokeism.

Those unions and activists have followed the path of Antonio Gramsci’s war of position to achieve an ultimate war of maneuver, which would be a complete acceptance of homosexual acts, gay marriage, abortion on demand, and other arguably unreasonable elements of DEI. Trump’s re-election suggests that a large portion of the electorate is not supportive of an administrative/bureaucratic state attacking faith and reason.

The following paragraphs from the Compendium of the Social Doctrine of the Church highlight the importance of this concern:

Connected with de facto unions is the particular problem concerning demands for the legal recognition of unions between homosexual persons, which is increasingly the topic of public debate. Only an anthropology corresponding to the whole truth of the human person can give an appropriate response to this problem with its different aspects on both the societal and ecclesial levels. The light of such anthropology reveals “how incongruous is the demand to accord ‘marital’ status to unions between persons of the same sex. It is opposed, first of all, by the objective impossibility of making the partnership fruitful through the transmission of life according to the plan inscribed by God in the very structure of the human being. Another obstacle is the absence of the conditions for that interpersonal complementarity between male and female willed by the Creator at both the physical-biological and the eminently psychological levels. It is only in the union of two sexually different persons that the individual can achieve perfection in a synthesis of unity and mutual psychophysical completion”.

The solidity of the family nucleus is a decisive resource for the quality of life in society. Therefore, the civil community cannot remain indifferent to the destabilizing tendencies that threaten its foundations at their very roots. Although legislation may sometimes tolerate morally unacceptable behaviour, it must never weaken the recognition of indissoluble monogamous marriage as the only authentic form of the family. It is therefore necessary that the public authorities “resist these tendencies which divide society and are harmful to the dignity, security and welfare of the citizens as individuals, and they must try to ensure that public opinion is not led to undervalue the institutional importance of marriage and the family”. (pars. 228-229)

The administrative state grants public sector unions too much power

Beginning in 2009, the United States has had more union members in public jobs than in the private sector, in terms of percentage of the workforce, in each respective industry.²⁰

In January 2025, the Bureau of Labor Statistics reported that 9.9% of the wage and salary workers in the United States were union members, a decline from over 20.1% in 1983. There were 3.4 million fewer labor union members in 2024 than in 1983. The number of union members in the United States has declined in absolute terms over the past 41 years and is expected to continue declining.

The percentage of union members who have government jobs (members of public sector unions) is now at 32.2 percent, which is five times the rate of union membership in the private sector. Today, union membership is much more common in government work than in private enterprises. However, in absolute numbers, the U.S. has 7.2 million union members in the private sector and 7 million in the public sector.²¹

As Pope Leo XIV realizes, artificial intelligence has become a serious threat to the income and meaning that good work provides people. While acknowledging the importance of the freedom of association in society (e.g., labor unions), he clearly recognizes that AI is now the most significant challenge to work life as we know it. His papal name significantly acknowledges Leo XIII, who faced the challenges of the Industrial Revolution. How will Catholics and others respond to the wonders, possibilities, and serious challenges of AI?

Attorney Philip Howard, the author of Not Accountable: Rethinking the Constitutionality of Public Employee Unions, argues that government employees have gained too much control over the government. The public employees’ political and collective bargaining power has weakened and compromised the roles of elected officials and their political appointees. The current Department of Government Efficiency (DOGE) efforts manifest the populace’s concern that the seat of authority is in the hands of career bureaucrats, their staffs, and public workers, rather than the electorate and their elected officials.

The first few months of President Trump’s second term have led to layoffs, reassignments, and the repeal of previous executive and administrative policies. It is interesting to note that, in the first half of the 20th century, neither Franklin D. Roosevelt nor President George Meany of the AFL-CIO believed unions were appropriate in government work due to the tension between collective bargaining and the provision of government services.

Over the last 60 years, the influence of public employee union members, particularly in terms of political power and workplace decision-making, has diminished the authority of elected officials and the appointed administrators of government programs, as well as weakened legitimate oversight duties. The managerial authority declined because public sector unions have increased their influence in political elections and workplace policies. Attempts at reform are now occurring through DOGE.

No one should take pleasure in the fact that a person is fired or feels pressured to leave a job or to take early retirement. Becoming unemployed can be traumatic. One assumes that the majority of public employees are dedicated individuals who strive to fulfill their assignments by serving the public and working as responsible colleagues. It is also safe to say, given the reality of U.S. woke activists in public sector unions (e.g., LGBTQ+ union caucuses), that government employees and unions can take ideological positions that discriminate against reasonable people of faith. The 2024 Republican electoral success has led to the swift elimination of DEI’s ideologically sponsored initiatives and requirements. Trump and his administration have responded to the voters.

Any reflective person can imagine that in recent times, some job seekers may not have applied for public sector jobs because they did not feel they fit the political and social culture of the organization or department. In a woke media, academic, and entertainment-dominated world, one can also venture to say non-woke people often could not get past the employment interview, had limited career prospects, or felt alienated from their peers in numerous public workplaces.

Philip Howard points back to the 1960s rights revolution as empowering public workers to make demands for their labor rights under the broader cultural demand of Civil Rights, Women’s Rights, and so on. Anyone old enough to recall the 1960s will also remember the force of the sexual revolution and, with some analysis, link that decade to today’s demands for sexual identity rights of the LGBTQ+ advocates. The demand for rights within DEI is limitless.

Observant and discerning thinkers also recognize that a person’s rights entail duties, limits, and boundaries in relation to others. Politicians, faced with the multitude of rights issues they encountered, inevitably responded to the public sector workers and unions that began to exert power in the 1960s. Howard describes the relationship as somewhat akin to collusion because politicians and public employees are bargaining over the use of taxes rather than the division of private sector profits.²² And the politicians in their legislative and executive roles are receiving substantial campaign donations and the support of get-out-the-vote networks from unions.

The crux of the public sector collective bargaining dilemma is that elected political leaders are expected to work for the public good, not the debatable special interests and ideological causes of some public sector employees and their unions. For Howard and others, this is a “constitutional flaw” when bargaining with public employee unions.²³

In the case of many state and municipal employees, contracts are not simply about wages and benefits; they are often full of detailed work rules and regulations. If you can think of any element of public service work, you can attach a rule to it. Due to collective bargaining agreements, managers often have limitations on their interactions with employees. Additionally, it is not uncommon for some public workers, particularly police and fire personnel, to retire after 25 or 30 years of service.²⁴ Public employee pension plans are now a significant financial burden for state and local governments.

Government work is no longer stained by rampant political patronage, when politicians handed out public works jobs as political spoils. In this era, however, public sector bargaining and union representation often lead to self-interested power brokering within the legislative branch and within government workplaces. When government employees observe co-workers’ debatable agendas and actions unaccounted for, they can lose the public service spirit that was a prominent element of Civil Service work life in earlier times. Such culture war positioning and maneuvering within the government also alienates citizens.

A specific public employee concern: Teachers’ unions

Public teacher unions oppose vouchers, alternative schools, and homeschooling, and they lend their support to politicians who share their views. This is an injustice to the many parent-citizens and their children who favor such programs, but these options will inevitably become more appealing with time.

Considering union leaders and social activists who support radical choices in the postmodern mindset, why should they not allow parents and their children to have a choice in education? Why do they put up borders and boundaries around faith when their postmodernism illogically advocates no boundaries? Public teacher unions and Planned Parenthood, the catechism of public schools, consistently promote the same legislation and endorse the same woke politicians.

Even with the 2018 Supreme Court decision in Janus v. AFSCME, which permits a public worker/non-union member to opt out of paying union agency fees, the National Education Association and the American Federation of Teachers are actively working with politicians to solidify their power in public schools with rules that cancel the First Amendment rights of non-woke educators and non-woke parents and their children.²⁵

Catholics and others of goodwill have a responsibility to inform the broader community about the inconsistencies, illogic, and injustices inherent in specific teacher-labor initiatives.

Endnotes:

¹ Dorr, Donal, Option for the Poor: A Hundred Years of Catholic Social Teaching, Maryknoll, New York: Orbis Press, 1992, p. 15.

² Ibid., p. 62.

³ Ibid., p.78.

⁴ Ibid., p. 75.

⁵ Ibid., p. 189.

⁶ Ibid., p. 304.

⁷ Centesimus Annus, para. 7.

⁸ Executive Order 10988, The American Presidency Project, Sec. 2.

⁹ “Federal Labor Relations Authority, A Short History of the Statute”.

¹⁰ “Postal Strike and Reorganization: Reinventing the System, Smithsonian National Museum”.

¹¹ Simon, Julia, and Kenny Moore, “Looking Back On When President Reagan Fired The Air Traffic Controllers”, Morning Edition, NPR.

¹² Civil Service Reform Act, Ballotpedia.

¹³ Friel, Brian, Bush, unions tangle over national security exemption to labor laws, Government Executive, August 16, 2002.

¹⁴ Swan, Jonathan, “AFL-CIO leader: Clinton, Obama let down the unions”, Axios, Feb. 7, 2021.

¹⁵ Ballotpedia, Presidential Executive Order 13836 (Donald Trump, 2018).

¹⁶ Ibid.

¹⁷ Judge Ketanji Brown Jackson’s Supreme Court Confirmation Hearing.

¹⁸ Balz, Dan, Washington Post, Democrats are in trouble, and a provocative analysis offers ideas to repair the party, Feb. 22, 2025.

¹⁹ The White House, “Restoring Accountability to Policy-Influencing Positions Within the Federal Work Force”, Jan. 20, 2025. Available at: https://www.whitehouse.gov/presidential-actions/2025/01/restoring-accountability-to-policy-influencing-positions-within-the-federal-workforce/, (accessed June 7, 2025).

²⁰ Disalvo, Daniel, National Affairs. 2010-09-17.

²¹ Bureau of Labor Statistics, U.S. Dept. of Labor, Union Members 2024, USDL-25-0105.

²² Howard, Philip K., Not Accountable: Rethinking the Constitutionality of Public Employee Unions, Rodin Books: Garden City, New York, 2023. Kindle eBook, p. 30-33.

²³ Ibid., p. 40.

²⁴ Ibid., p.75.

²⁵ Ibid., p. 112.