“Our conclusion that Peltz-Steele is overreading the passages from Janus in question draws further support from another passage in Janus itself that Peltz-Steele ignores. In explaining that the union’s asserted need to charge nonunion employees agency fees to cover the costs of representing such employees in grievance proceedings did not supply a sufficiently compelling state interest to overcome heightened review, the Court noted that unions could instead use a ‘less restrictive’ system in which nonmember employees pay for such services only if they use them—or simply deny representation to nonmembers in grievance proceedings altogether,” Chief Judge David J. Barron wrote on behalf of the unanimous panel.