Keller (1990): This case involved compulsory fees to the state
bar. The U.S. Supreme Court held that the state bar could require
lawyers to pay fees since the compelling interest—“regulating the
legal profession and improving the quality of legal services”—was a
compelling state interest that outweighed individual First Am.
rights. The bar could spend money on things related to this
interest, such as disciplining members or proposing new ethical
rules. But the state bar could not spend money on ideological issues
not related to this interest, such as gun control or a nuclear weapons freeze.
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