"It is well-recognized that if you take away the mechanism [unified dues and payroll deduction] you won't collect a penny from these people, and it has nothing to do with voluntary or involuntary. I think is has to do with the nature of the beast, who are our teachers, simply don't come up with the money regardless of the purpose." Robert Chanin, NEA General Counsel, U.S. District Court oral argument, 1978.