# Janus v. AFSCME *2018 U.S. Supreme Court decision holding a public-employee union-fee mandate unconstitutional as compelled subsidization of speech* *Janus v. AFSCME, Council 31*, 585 U.S. 878 (2018), is a decision of the Supreme Court of the United States on a mandate requiring public employees to pay fees to a union. The decision held that the public-employee union-fee mandate compelled subsidization of speech and was unconstitutional.[^1] In this wiki's claim:link record, the decision appears in two validated pairs under Theory 7, the First Amendment (Free Exercise and Free Speech, compelled-speech) theory.[^2][^3] One pair records the holding.[^2] The other links the decision's compelled-speech analysis to a "PHJ-form affirmation requirement."[^3] The record does not identify the form, the body that imposes the requirement, or any proceeding in which the *Janus* analysis has been applied to it.[^3] ## What The decision concerned a mandate that public employees pay union fees. It held that the mandate compelled subsidization of speech and was unconstitutional.[^1] The project's catalogue files the holding under the First Amendment compelled-speech theory.[^2] ## When The decision is reported at 585 U.S. 878 and dates from 2018.[^1] The record does not give the dates of argument or decision.[^1] ## In the Minnesota record ### What - Pair 27 of the project's *1,400 validated pairs across 14 legal theories* records *Janus* for the holding that a public-employee union-fee mandate compelled subsidization of speech and was unconstitutional.[^2] - Pair 69 records the *Janus* compelled-speech analysis as applicable to a "PHJ-form affirmation requirement." This is the project's claim link. The pack carries no court or agency ruling applying *Janus* to that requirement.[^3] ## Notes [^1]: Supreme Court of the United States, *Janus v. AFSCME, Council 31*, 585 U.S. 878 (2018) — public-employee union-fee mandate compelled subsidization of speech; unconstitutional. https://supreme.justia.com/cases/federal/us/585/878/ [^2]: Minnesota wiki claim:link record, *Theory 7 — First Amendment (Free Exercise + Free Speech / Compelled Speech)*, pair 27 — catalogues *Janus* for the union-fee holding. https://supreme.justia.com/cases/federal/us/585/878/ [^3]: Minnesota wiki claim:link record, *Theory 7 — First Amendment (Free Exercise + Free Speech / Compelled Speech)*, pair 69 — links the *Janus* compelled-speech analysis to a PHJ-form affirmation requirement. https://supreme.justia.com/cases/federal/us/585/878/