in both “basic considerations of fairness” and “concern for the First Amendment rights at stake,” 475 U.S. at 306, 106 S.Ct. at 1076, indicating that its disclosure requirements were not exclusively the product of First Amendment concerns. It is, of course, conceivable in the abstract that the content of the duty of fair representation under the NLRA might not coincide with that of the “basic considerations of fairness” discussed in Hudson. But we are persuaded that nonmembers cannot make a rehable decision as to whether to contest their agency fees without trustworthy information about the basis of the union’s fee calculations, cf. Hudson, 475 U.S. at 306, 106 S.Ct. at 1075-76, and that an independent audit is the minimal guarantee of trustworthiness. See Miller, 108 F.3d at 1420 (<HOLDING>); Abrams, 59 F.3d at 1379 n. 7 (same).
holding that procedural bar rule does not apply to ineffectiveness claims holding that governments asserted interest in protecting the privacy of arrestees is substantial under central hudson holding that inmates fourth amendment protection from unreasonable strip searches survives hudson holding that even after hudson the prisoners privacy interest in the integrity of his own person is still preserved under bell holding that similar procedural obligations apply under nlra and hudson