Whether Lathrop and Keller should be overruled and 'integrated bar' arrangements like Wisconsin's invalidated under the First Amendment

QUESTION PRESENTED In Janus v. AFSCME, 138 S. Ct. 2448 (2018), the Court held that State laws compelling public employees to subsidize the speech of labor unions violate the First Amendment, overruling Abood v. Detroit Board of Education, 431 U.S. 209 (1977). The same improperly “deferential standard” that Abood espoused underpins the two decisions of the Court—Lathrop v. Donohue, 367 U.S. 820 (1961), and Keller v. State Bar of California, 496 U.S. 1 (1990)—permitting States like Wisconsin to compel attorneys to be members of an “integrated bar” and fund its speech and advocacy on matters of substantial public concern. Accordingly, the question presented is: Whether Lathrop and Keller should be overruled and “integrated bar” arrangements like Wisconsin’s invalidated under the First Amendment.