“An Aliquot Portion of Their Dues:” A Survey of Unified Bar Compliance with Hudson and Keller

This article provides a survey of unified bar associations nationwide and the compliance requirements following two United States Supreme Court Cases: Keller v. State Bar of California and Chicago Teachers Union v. Hudson. In sum, Keller requires unified bar associations to establish a procedure to ensure that membership dues were not used for political or ideological activities where the paying member of said dues objects to that use. Similarly, in Hudson, the Court recognized that unified bar members have a right to an adequate explanation of the basis for the amount of their mandatory dues. The author reviewed these two Supreme Court cases and then considered both successful and unsuccessful procedures take by unified bar associations that have evolved in order to comply with the requirements of Hudson and Keller. Ultimately, the author suggests steps current non-complying unified bar associations might take to satisfy their obligation to dissenting members under Hudson and Keller.