Do a union and employer violate the Railway Labor Act by requiring non-members to financially support a union in a manner not authorized by statute, and does a union violate its duty of fair representation by denying contractual benefits to non-supporting employees?

The Railway Labor Act (“RLA”) , 45 U.S.C. § 152 (Fourth), prohibits “influenc[ing] or coerc[ing] employees in an effort to induce them to join or remain … members of any labor organization,” with one exception. 45 U.S.C. § 152 (Eleventh) (a) permit s unions and employers “to make agreements, requiring as a condition of continued employment, that … all employees shall become members of the labor organization representing their craft or class[.]” The duty of fair representation (“DFR”) “require[s] the union … to represent non -union … members of the craft without hostile discrimination, fairly, impartially, and in good faith.” Steele v. Louisville & N.R. Co., 323 U.S. 192, 204 (1944) . The questions presented are : 1. Do a union and employer violate § 2, Fourth by requiring non-members to financially support a union in a manner not authorized by § 2, Eleventh (a)? 2. Does a union violate the DFR by denying contractual seniority benefits and bidding privileges to non-member employees who do no t financially support the union ?