Under a 1944 Supreme Court ruling and federal and state laws, governments can force individual workers in unionized workplaces to be represented by unions, regardless of whether they are union members. Per the 1944 ruling, these workers do not have the "freedom" to negotiate "better terms" with their employers. This differs from Western Europe, where employees and employers are generally free to negotiate with each other. In the 2018 case of Janus v. AFSCME, the U.S. Supreme Court ruled (5-4) that governments cannot force public-sector workers who are not union members to pay union dues, but this does not stop governments from forcing them to be represented by unions. As of October 2019, the National Right to Work Legal Defense Foundation is unaware of any private-sector workplace where individual workers are free to bargain for themselves where a union is formally established.