On March 29th, the U.S. Supreme Court deadlocked 4-4 in the case of Friedrichs v. California Teachers Association, a closely-watched case on the constitutionality of fees public unions charge non-members.  In the Supreme Court, a tie has the effect of affirming a lower court decision, which in this case had gone in favor of the union.  Justice Antonin Scalia, who died on February 13th, had been expected to cast the deciding vote against the union, but his death resulted in…