BOYCE F. MARTIN, Jr., Circuit Judge.
This case involves yet another challenge to a labor arrangement sanctioned by the Michigan Public Employment Relations Act. Under the Act, any public school employee who is not a member of his or her local education association may be required nonetheless to pay a service fee to the local association for its costs of statutory exclusive representation. MICH.COMP.LAWS § 423.211. In Abood v. Detroit Board of Education,
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