In its 2018 ruling in Janus v. AFSCME, the Supreme Court held that public employees have a First Amendment right not to be compelled to subsidize union speech on matters of substantial public concern. This interesting certioriari petition in Fleck v. Wetch, filed by the Goldwater Institute on behalf of a North Dakota attorney, presents the question whether post-Janus a state can force attorneys to join, and thus subsidize the political speech of, bar associations as a condition of practicing law.