Many states have had contentious disputes over collective bargaining rights recently. In December Michigan approved legislation [JURIST report] known as "Freedom to Work" that makes payment of union dues voluntary and limits workers' ability to strike. In September the Michigan Supreme Court ordered [JURIST report] a union-backed measure to amend the state constitution to include a right to labor unionization and collective bargaining to appear on the November ballot. The measure was defeated 57-43 percent [AP report]. Wisconsin faced a challenge against its legislation which limited the collective bargaining rights of public employee unions. In July the Wisconsin Supreme Court ruled [JURIST report] not to reopen a case challenging the state's Budget Repair Bill [text, PDF] because of a justice's refusal to recuse himself. Four votes were needed, but only three justices were in support of reopening the case. The court upheld [JURIST report] the bill in June 2011 thereby overruling the Dane County Circuit Court [official website] finding [JURIST report] a month earlier that legislators had violated the "open meetings" rule. The court ruled that the lower court had "invaded the legislature's constitutional powers." In March a judge for the US District Court for the Western District of Wisconsin [official website] ruled unconstitutional [JURIST report] certain provisions of the Budget Repair Bill reasoning that unions which supported Governor Scott Walker [official website] during his election were apparently given preferential treatment. In November 2011 Ohio voters rejected [JURIST report] a bill which would have impacted Ohio's 400,000 public workers by limiting their ability to strike and collectively bargain for health insurance and pensions.