On August 31, 2016, I reported on a case before the Idaho Federal District Court, in which the International Union of Operating Engineers attacked Idaho’s right to work law on 5th Amendment “takings” and preemption grounds. Late last month, U.S. District Judge Howard J. Lodge ruled that the National Labor Relations Act does not preempt Idaho’s right to work law and that there was no unlawful taking of union dues by forcing unions to represent workers who don’t pay union dues. The union has vowed to appeal the dismissal to the 9th Circuit Court of Appeals. We will follow that appeal and update you when important issues arise.