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(d)Creating criminal sanctions for violation of laws relating to the display
                          for sale of drug paraphernalia to minors;
                          (e) Creating an unlimited exclusion from gift  tax for  gifts to  pay for
                              education tuition and medical care;
                          (f) Providing that life imprisonment without parole shall apply to minors
                              tried as adults and convicted of murder;
                          (g) Requesting Congress to refrain from permitting the importation  of
                              workers from other countries.


                       Petitioners  sought an  injunction  restraining  the State Bar  from  using
                                                                                                 8
               mandatory bar dues to advance political or ideological causes or beliefs.   The trial

               court granted  summary judgment  in favor of  the Bar  on  grounds  that it is a

               governmental agency and therefore  permitted to engage  in the challenged

                          9
               activities.   The court of appeals reversed, holding that the activities of the State
               Bar were akin to activities of a labor union.      10   The Supreme Court of California

               held that  the  State Bar’s status  as  a public  corporation  made it a government

               agency.  11   The Court distinguished other cases subjecting the expenditures of state

               bar associations to  First  Amendment scrutiny,  such as  Gibson v. The Florida

               Bar, 12   on grounds that  none of the associations involved in those cases rested

               upon a constitutional and  statutory structure comparable to the California State

               Bar. 13

                       The U.S. Supreme Court reversed.  The Court initially referred to Lathrop v.

               Donohue,   14  in which a Wisconsin lawyer claimed he could not constitutionally be

               compelled to join and financially support a state bar association which expressed



                       8 See Keller, 767 P.2d at 1022.
                       9 See Id. at 1023
                       10 See Id.
                       11 See Id. at 1029.
                       12 798 F.2d 1564 (11th Cir. 1986).
                       13 See Keller, 767 P.2d at 1028.
                       14 367 U.S. 820, 81 S.Ct. 1826 (1961).

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