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opinions on, and attempted to influence, legislation. The Court in Lathrop said the

bulk of state bar activities served the function of elevating the educational and

ethical standards of the bar to the end of improving the quality of legal service

available to the people of the state, without any reference to the political process.

This is a legitimate end of state policy. 15 The Lathrop Court said that the

Supreme Court of Wisconsin may constitutionally require that the cost of

improving the profession should be shared by the lawyers, even though the

organization engages in some legislative activity. 16
But the plurality in Lathrop reserved judgment on plaintiff’s additional

claim that his free speech rights were violated by use of mandatory dues to support

objectionable political activities, believing the record was not sufficiently

developed to address the issue. 17 That issue was squarely presented in Keller.

In reaching its decision, the Court relied upon Abood v. Detroit Board of

Education. 18 At issue in Abood was whether agency-shop dues of nonunion

public employees could be used to support political and ideological causes of the

union which were unrelated to collective bargaining activities. The Court held that

while the Constitution did not prohibit a union from spending funds for the

expression of political views, it did require that such expenditures be financed from

charges or dues paid by employees who did not object to advancing those ideas
19
and who were not coerced into doing so against their will. The Court quoted

Thomas Jefferson’s view that "to compel a man to furnish contributions of money

for the propagation of opinions which he disbelieves, is sinful and tyrannical." 20

15 See Id. at 842-43.
16 See Id.
17 See Id. at 827-28.
18 431 U.S. 209, 97 S.Ct. 1782 (1977).
19 See Id. at 235-236.
20 Id. at 234.

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