The Labor Management Relations Act of 1947 (also known as the Taft-Hartley Act) made the closed shop illegal in the United States. Subsequently, the union shop was also deemed to be illegal. The Supreme Court in "Pattern Makers v. NLRB", 473 U.S. 95 (1985), also held that a union member may resign from the union at any time without notice, thereby enabling the worker to work during a strike without being subject to sanctions from the union. Under the National Labor Relations Act (NLRA), as amended by the Taft-Hartley Act, and held by the Supreme Court in "Communications Workers of America v. Beck", in a union security agreement, unions are authorized by statute to collect from non-members only those fees and dues necessary to perform its duties as a collective bargaining representative known as agency fees. Compelling payment of agency fees from non-union employees in the public sector was held unconstitutional in "Janus v. AFSCME", in June 2018. The agency fee is that portion of union dues that is attributable to the cost of representing employees in collective bargaining and in providing services to all represented employees, but not, with certain exceptions, to the union's political activities or organizing employees of other employers. Additional restrictions apply to unions covered by the Railway Labor Act (RLA) and unionized governmental employees.