(Compulsory financial support of SEIU 925 is a violation of 42 U.S.C. § 1983   and the United States Constitution)   (Exclusive representation in violation of 42 U.S.C. § 1983   and the United States Constitution)   (Limited to Count II)   11. Washington's family child care providers care for a child or children in the home of  the provider or in the home of the child or children throughout all hours of the day, and in certain  circumstances overnight and on weekends. Providers may receive child care subsidies for their  care of children. Providers are either licensed by the state under RCW 74.15.030 or are exempt  from licensing under chapter 74.15 RCW. RCW 41.56.030.    12. Reimbursements to family child care providers are funded through public programs  such as Working Connections Child Care ("WCCC"), Washington's largest-such program, that  subsidize child care for qualified low-income working families.1 WAC 170-290-0001; WAC  170-290-0240.   32. Plaintiffs re-allege and incorporate by reference the paragraphs set forth above.   36. Plaintiffs re-allege and incorporate by reference the paragraphs set forth above.   37. By and through RCW 41.56.113(1)(b)(i), along with Article 5 of the CBA prior to the  September 18, 2014, MOU, and related acts, as well as the automatic seizure of dues equivalent  fees from Plaintiffs and class members, unless they specifically opted out and requested the  deductions to cease, Defendants have compelled Plaintiffs, and on information and belief,  continue to compel other family child care providers to financially support SEIU 925 as their  mandatory representative for petitioning and contracting with the State. By so doing, Defendants  have violated, and continue to violate, the First Amendment rights of Plaintiffs and other child  care providers, as secured by the Fourteenth Amendment to the United States Constitution and  42 U.S.C. § 1983, not to associate with a mandatory representative and not to support, financially  or otherwise, petitioning and speech.    40. Plaintiffs bring this case as a class action pursuant to Federal Rules of Civil Procedure  23(b)(3), for themselves and for all others similarly situated. The class for Count II consists of all  family child care providers who are not members of the union but from whom the State deducted  dues equivalent fees from their payments and remitted to SEIU Local 925 and its affiliates. The  class includes everyone who comes within the class definition at any time from March 5, 2012,  until the conclusion of this action.   41. According to Local 925’s 2013 LM-2 Annual Report filed with the United States  Department of Labor, there are more than 3,000 class members. Their number is so numerous in  varying locations and jurisdictions across Washington that joinder is impractical.   42. There are questions of law and fact common to all class members, including  Plaintiffs. Factually, all class members were, or may still be, compelled financially to support  SEIU Local 925 as their state-designated representative for the purposes of speaking to,  petitioning, and otherwise lobbying the State and its officials with respect to limited aspects of  the child care subsidy programs. The question of law is the same for all class members: does this  violate the First Amendment’s least restrictive means test and constitute a prior restraint on class  members’ speech.   I. Family Child Care Providers and the State of Washington.  