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The reasoning of compelled-speech cases has been carried over to certain instances in which individuals are compelled not to speak, but to subsidize a private message with which they disagree. Thus, although the court has upheld state-imposed requirements that lawyers be members of the state bar and pay its annual dues, and that public school teachers either join the labor union representing their 'shop' or pay 'service fees' equal to the union dues, the court has invalidated the use of the compulsory fees to fund speech on political matters. See Keller v. State Bar of Cal., 496 U. S. 1 (1990); Abood v. Detroit Bd. of Ed., 431 U. S. 209 (1977). Bar or union speech with such content, the court held, was not germane to the regulatory interests that justified compelled membership, and accordingly, making those who disagreed with it pay for it violated the First Amendment. See Keller, supra, at 15-16; Abood, supra, at 234-235. 


The Supreme Court held that commercial speech, usually defined as speech that does no more than propose a commercial transaction, is protected by the First Amendment. Virginia Bd. of Pharmacy v. Virginia Citizens Consumer Council, Inc., 425 ...

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