The U. S. Supreme Court's 1991 decision in Lehnert v Ferris Faculty Association113 discovered that 90 percent of the NEA, MEA, and local union fees being charged to objecting faculty members was spent on union activities unrelated to collective bargaining. The Court again upheld the principle that objecting fee payers cannot be compelled to pay for a union's lobbying, organizing, image building, public relations, or any other activities not directly related to collective bargaining representation. The Court also required the union to provide an audited accounting to objecting fee payers.

Buzenius v NLRB