File v. Martin

Dist. Ct. did not err in dismissing plaintiff-attorney’s action that challenged on First Amendment grounds Wisconsin Supreme Ct. rule that requires Wisconsin lawyers to join and pay annual dues to State Bar of Wisconsin, where failure to do so subjects said attorneys to automatic suspension. Dist. Ct. correctly found that plaintiff’s action is foreclosed by U.S. Supreme Ct. decision in Keller, 496 U.S. 1, which held that compelled association required by integrated bar is justified by State’s interest in regulating legal profession and improving quality of legal services. Ct. rejected plaintiff’s claim that Keller had been implicitly overruled by U.S. Supreme Ct. decision in Janus, 138 S.Ct. 2448, and further noted that although underlying basis of Keller has been overruled, Keller remains good law, since only U.S. Supreme Ct, can overrule its own decisions, and it has refused to overrule Keller.