10. When Gervais began her employment with Port Huron, she signed MEA’s joint member- ship application and dues check-off authorization form in, or about, August 1991 based on the  union representative’s statements that union membership was an employment condition.    11. On, or about, September 25, 2013, Gervais notified PHAES and MEA by written letter re- signing her union membership at all levels (“resignation”) and revoking her check-off authorization  (“revocation”).    12. On January 30, 2018, MEA, through its debt collection attorney, demanded, by letter,  Gervais pay dues and/or fees in the amount of $647.30 that had accrued between her September  25, 2013 resignation from union membership and her July 1, 2014 retirement from employment,  4  and further attempted to collect those dues and/or fees by threatening a small claims court collec- tion action for her failure to pay them.    13. Gervais has not paid any dues and/or fees to MEA or its affiliates that accrued after her  September 25, 2013 resignation and revocation.   14. Since October 10, 1997, Plaintiff Williams has been employed by Port Huron as a  full-time Secretary I within a bargaining unit represented by PHAES with assistance from its affili- ate MEA.    15. After Williams began her employment with Port Huron as a Secretary I, she signed MEA’s  joint continuing membership application and dues check-off authorization form on January 12,  1998 based on the information and belief that both were employment conditions.    16. On, or about, September 17, 2013, Williams notified PHAES and MEA by written letter,  via certified mail, return receipt requested with the U.S. Postal Service, of her resignation and rev- ocation.     17. On at least thirty-two occasions since January 15, 2015, MEA monthly has demanded, by  e-mail, Williams pay dues and/or fees in the amount of $622.39 that had accrued after her Sep- tember 17, 2013 resignation.    18. On January 11, 2017, MEA demanded, by letter, Williams pay dues and/or fees in the  amount of $622.39 that had accrued after her September 17, 2013 resignation and revocation, and  further attempted to collect those dues and/or fees by threatening to send her matter to its collec- tions law firm for her failure to do so, which firm would pursue any and all available legal options  to obtain the alleged outstanding balance.    19. On May 25, 2018, MEA, through its collections law firm, demanded, by letter, Williams  pay dues and/or fees in the amount of $622.39 that had accrued after her September 17, 2013 res- 5  ignation and revocation, and further attempted to collect those dues and/or fees by threatening a  small claims court collection action for her failure to pay them.    20. Williams has not paid any dues and/or fees to MEA or its affiliates that accrued after her  September 17, 2013 resignation and revocation.   21. On information and belief, MEA acts as the collection agent for itself, its parent affiliate,  the National Education Association, and the local affiliates, including PHAES, in demanding, at- tempting to collect, and/or actually collecting dues, fees, and/or payments from Gervais, Williams,  and the putative Class and then in distributing those dues, fees, and/or payments amongst its affili- ates.   22. On June 27, 2018, the Supreme Court in Janus held it unconstitutional for a union to at- tempt to collect dues, fees, and/or payments or require a non-member to financially support the  union without the employee first affirmatively having consented to pay and having waived his or  her First Amendment rights. 138 S. Ct. at 2486.  23. This is a class action brought by the named Plaintiffs on their own behalf and on behalf of  all others similarly situated, pursuant to Federal Rule of Civil Procedure 23(b)(1)(A), (b)(2), and/or  (b)(3). The Class consists of all public employees from whom MEA, its affiliates, and/or its agents  have demanded, attempted to collect, and/or actually collected union dues, fees, and/or other  payments for times during which the employee affirmatively had not consented to pay those mon- ies. The Class includes everyone who comes within the Class definition at any time from three (3)  years prior to the date of this action’s filing until its conclusion for the period they meet the Class  definition.     6   24. Upon information and belief, the number of persons in the Class is in the hundreds, as  MEA represents approximately 23,000 non-member employees in Michigan. These persons are  therefore so numerous that joinder of the entire Class is impractical. Their number makes joinder  of the entire Class impractical.   25. There are questions of law and fact common to all Class members, including Plaintiffs.  Factually, all Class members are non-union members who are subject to the same, or similar,  MEA’s, its affiliates’, and/or its agents’ demands for payment, attempts to collect, and/or actual  collection of union dues, fees, and/or payments. The question of law is the same for all Plaintiffs  and Class members:  whether MEA violated their First Amendment rights by demanding pay- ment of, attempting to collect, and/or actually collecting union dues, fees, and/or payments from  non-members in violation of Janus.    26. The named Plaintiffs’ claims are typical of other Class members’ claims as the Class mem- bers are subject to the same infringement of their constitutional rights and interests caused by  MEA’s, its affiliates’, and/or its agents’ demands, attempts to collect, and/or actual collection of  union dues, fees, and/or payments from non-members without written authorization and a legal  waiver of their constitutional rights.    27. The named Plaintiffs adequately can represent the Class’s interests. They have no interests  antagonistic to other non-members who are subject to MEA’s, its affiliates’, and/or its agents’ de- mands for, attempts to collect, and/or actual collection of dues, fees, and/or payments from  non-members.    28. Because MEA, its affiliates, and/or its agents are demanding payment of, attempting to col- lect, and/or actually collecting dues and/or fees from non-member employees it exclusively repre- sents in violation of the employees’ constitutional rights, the prosecution of separate actions by in- 7  dividual Class members would create a risk of inconsistent or varying adjudications which would  establish incompatible standards of conduct for MEA.   29. Because MEA, its affiliates, and/or its agents have demanded, attempted to collect, and/or  actually collected union dues, fees, and/or payments from Plaintiffs and the Class on grounds ap- plicable generally to the class, final injunctive relief and/or corresponding declaratory relief is ap- propriate.   30. A class action can be maintained under Rule 23(b)(3), because the common questions of  law and fact identified in paragraph 25 predominates over any questions affecting only individual  class members. A class action is superior to other available methods for the fair and efficient adju- dication of the controversy because, among other things, all Class members are suffering the same  violation of their First Amendment rights, but the amount of money involved in each individual=s  claim would make it burdensome for Class members to maintain separate actions.   31. Plaintiffs’ attorneys are provided to Plaintiffs and Class members pro bono by a national,  charitable legal aid organization. These attorneys are experienced in representing nonmember  employees in labor litigation, including issues similar to those presented here. Because of their ex- perience and expertise in this area of the law, these attorneys are best able to represent the Class  members’ interests, and fairly, zealously, and adequately will do so.  8. Michigan’s Public Employment Relations Act (“PERA”) authorizes MEA and other unions  to act as the exclusive bargaining representative of public employee units. MICH. COMP. LAWS  § 423.211.    9. Between August 1991 and July 1, 2014, Plaintiff Gervais was employed by the Port Huron  Area School District (“Port Huron”) at various times as an Account Clerk II, Secretary II, and  Account Clerk I within a bargaining unit represented by Port Huron Association of Educational  Secretaries (“PHAES”) with assistance from its affiliate MEA.  