In Barke, plaintiffs, who were “elected members of local California government bodies, including city councils, school boards, and community college and special purpose districts,” challenged Cal. Gov. Code § 3550. Id. at 14 (citing 25 F.4th at 716-17).
Our prior decision in Leonard v. Clark is instructive. 12 F.3d 885 (9th Cir. 1993), as amended (Mar. 8, 1994). Leonard involved a collective bargaining agreement that restricted a union's ability to "specifically endorse[ ] or sponsor[ ]" legislation that would benefit the union's members.
