The case of Eddie Keller et al. v. State Bar of California et al., 1989, revolved around the issue of whether mandatory dues paid by members to the State Bar could be used for political or ideological activities without violating their First Amendment rights. The plaintiffs, who were members of the California State Bar, argued that their compulsory fees should not fund activities unrelated to regulating legal profession and improving quality of legal services - purposes they considered legitimate state interests justifying forced association with a bar organization. They contended that using these funds for other purposes violated their freedom of speech and association rights under the U.S Constitution's First Amendment. In its decision, however, the Supreme Court ruled in favor of the defendants (State Bar), stating that as long as those expenditures are necessarily or reasonably incurred for regulation purpose or service improvement purpose mentioned above – even if they involve significant political/ideological elements – such use does not infringe upon member attorneys' constitutional rights.

In the dissenting opinion for Eddie Keller, et al. v. State Bar of California, et al., Justice Kennedy argued that compelling members of the state bar to fund political and ideological activities with which they disagree is a violation of their First Amendment rights. He contended that such compulsion infringes upon an individual's freedom not to associate and not to express certain views. Furthermore, he disagreed with the majority's view that integrated bars are justified in using member dues for political purposes because these activities are connected to regulating the legal profession or improving its quality. Instead, he believed this connection was too tenuous and could be used as a pretext for forcing individuals into supporting objectionable ideologies or causes under threat of losing their professional licenses.