In Lathrop v. Donohue, the U.S. Supreme Court was asked to consider whether mandatory membership in a state bar association violated an individual's First and Fourteenth Amendment rights. The case arose when a Wisconsin attorney objected to being compelled to join his state's integrated bar association, arguing that it infringed upon his freedom of speech and assembly by using his dues for political purposes with which he disagreed. In a split decision, the court ruled that compulsory membership did not violate constitutional rights as long as the organization used its funds for activities related directly to regulating legal practice and improving quality of legal services rather than engaging in political or ideological activities unrelated to such goals.

In the dissenting opinion for Lathrop v. Donohue, Justice Hugo Black and Justice William O. Douglas argued that mandatory membership in a state bar association violated an individual's First Amendment rights to freedom of speech and assembly. They contended that forcing lawyers to join these associations was akin to compelling them to endorse the views expressed by those organizations, even if they disagreed with them. The justices also pointed out that such forced memberships could potentially be used as tools of political coercion or suppression of dissent within the legal profession itself. Furthermore, they believed it was unconstitutional for states to condition one's ability to practice law on membership in any organization - including a state bar association.