As the employee had expressly agreed to pay the union by authorizing the paycheck deduction, and the contract for representation was valid under the state law of the time, the First Amendment right recognized by the courts after the contract had begun did not require an explicit waiver at the time of contractual formation; even under the new standard, any employee who consents to pay can be bound to the contract.
State law defining a public sector bargaining unit and establishing an exclusive representative organization for the bargaining unit does not violate First Amendment associational rights; plaintiff is not compelled to affiliate with the representative organization, and employees are free to form advocacy groups.