The freedom of association also includes the freedom not to associate. In certain employment circumstances, employees are required to contribute to a union as conditions of their employment (see Rand formula). However, mandatory associations do not invoke section 2(d) in and of themselves. In "Lavigne", the Court found that the right not to be associated extended only to where the association supported causes that went beyond what is necessary for employee representation. More generally, the Supreme Court had stated that the right is violated only when the mandatory association imposes "ideological conformity". Such violations have also mostly been found by the Supreme Court to be justified under section 1, resulting in a right not to associate that has more theoretical than practical effects.