KVIG Informative

A Las Vegas convention worker’s 2025 complaint against her own union rests on a law Nevada voters approved by barely a thousand votes seven decades earlier. The statute hasn’t moved since, but the fights over what it actually means keep landing in federal filings.

The Nevada Legislature moved first. On March 14, 1951, lawmakers approved Senate Bill 79, creating what is now Nevada Revised Statutes 613.130, an amendment to the state’s existing “yellow dog” statute barring employment agreements that require a worker to join or refrain from joining a labor organization, according to a background paper published by the Nevada Legislative Counsel Bureau’s Research Division.

Voters went further the following year. On Nov. 4, 1952, Nevadans approved a right-to-work initiative petition by a margin of 1,034 votes, according to the same Legislative Counsel Bureau paper. The measure became Nevada Revised Statutes 613.230 through 613.300, and the derivation notes attached to the current codified text trace the enacting language to the state’s 1953 compilation of session laws.

Voters were asked to reconsider twice in the years that followed and left the law in place both times. On Nov. 2, 1954, a repeal measure failed by 2,046 votes, with 38,480 Nevadans voting against repeal and 36,434 in favor, according to the Legislative Counsel Bureau paper. On Nov. 6, 1956, voters rejected a second repeal attempt by 7,248 votes and separately voted down a constitutional amendment on the same subject by 12,493 votes, the same paper states.

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The Legislature tried and failed to revisit the law repeatedly after that. Bills to amend or repeal the statute died without passing in 1959, 1961, 1971 and 1973, according to the Legislative Counsel Bureau paper, including a 1973 bill that would have repealed the law outright and a companion bill the same year that would have permitted union-shop contracts instead. Both died in the Assembly Committee on Labor and Management.

The operative language today sits in NRS 613.250, which bars denying a person the opportunity to obtain or retain employment because of nonmembership in a labor organization, according to the Nevada Revised Statutes as published by the Nevada Legislature. Surrounding sections in the same chapter define a labor organization, declare contracts that violate the section void, bar compelling union membership through strikes or boycotts, and authorize both damages and injunctions for violations, the statute shows.

Nevada’s largest hospitality union predates the law by nearly two decades. The Culinary Workers Union Local 226 was chartered on Nov. 1, 1935, according to the union’s own published history.

The union’s history credits Al Bramlet, elected secretary-treasurer in 1954, with growing membership from about 1,000 workers to 22,000 by the time of his 1977 death, in part by recruiting Black workers from the American South into Southern Nevada’s expanding hospitality industry, according to the union’s own account. That same history describes the 1953 codification of Nevada’s right-to-work law as a response to the union’s organizing strength — the union’s own characterization of why the law took the shape it did, not an independent finding.

The union built its membership through major work stoppages despite the legal ban on compulsory membership: a seven-day strike across Reno and Sparks in July 1949, a four-day strike against 16 Strip casinos in 1970 that the union’s history says was the first time those casinos went dark since opening, and a 16-day strike against 15 casinos in 1976 alongside musicians’ and stagehands’ unions, according to the same union history.

The longest of those fights, a strike against the Frontier that ran six years, four months and 10 days from 1991 to 1998, is described in the union’s own history as the longest and most successful strike in United States history, with no workers crossing the picket line for its full duration. Card-check neutrality agreements, which let workers organize without a secret-ballot election, became standard across Las Vegas Strip properties starting in 1989, the same history states, and union membership grew from about 18,000 workers in 1987 to roughly 60,000 by 2019.

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The law those decades of organizing worked around is still being tested in specific cases. On March 12, 2025, a Las Vegas Convention Center worker named Rebecca Swank filed an unfair labor practice charge with the National Labor Relations Board against Culinary Workers Union Local 226 and her employer, food-service contractor Sodexo. Swank, represented by the National Right to Work Legal Defense Foundation, alleged the union deducted full dues from her wages after she submitted two written letters resigning her membership and revoking her dues checkoff authorization, and that the union failed to produce documentation of any authorization she had previously signed.

Culinary Workers Union Local 226 Secretary-Treasurer Ted Pappageorge responded the next day, stating the union’s actions were lawful and that it expected to prevail, and describing the charge as one in a pattern of challenges from anti-union groups and Nevada gaming figures opposed to the union’s organizing, without directly addressing Swank’s specific dues-authorization allegation.

Nevada’s right-to-work law bars a union from making membership or dues a condition of employment. It does not, on its own, resolve what happens when a worker says she revoked her authorization and the union kept deducting anyway. That gap between the 1952 ballot measure’s plain text and its application to one Las Vegas paycheck 73 years later is now a federal case, decided the way most disputes over this statute eventually are — one worker, one filing, one union asked to show its math.