10.2190/HXEF-EXH6-15RT-C27W HXEFEXH615RTC27W 0 RESTRICTIONS ON THE USES OF UNION DUES: A THREAT TO PUBLIC SECTOR UNIONS? 20020509 20020509 20020509 20020509 http://baywood.metapress.com/link.asp?target=contribution&id=HXEFEXH615RTC27W 1 JAN W. HENKEL AND NORMAN J. WOOD The U. S. Supreme Court previously had established that funds collected through union shop agreements could not be used for activities unrelated to collective bargaining. On April 25, 1984 the Supreme Court in <em>Ellis v. Brotherhood of Railway, Airline and Steamship Clerks</em> adopted a new test for evaluating union expenditures. In addition, the court for the first time illustrated which activities are considered to be germane to collective bargaining. The <em>Ellis</em> decision arose in the private sector. This article discusses the applicability of the <em>Ellis</em> reasoning to labor relations in public sector employment.