Plaintiff Scott Lautenbaugh seeks preliminary injunctive relief to redress and prevent further deprivation of rights protected by the First and Fourteenth Amendments to the United States Constitution by actions of Defendants. Specifically, Plaintiff Lautenbaugh seek to enjoin actions by the NSBA, under color of state law, that compel speech and compel association by Plaintiff Lautenbaugh and the other class members he seeks to represent. The NSBA?’s unlawful actions are the result of the NSBA?’s imposition of mandatory bar dues as a condition of membership to the NSBA, a portion of which are used to fund political, ideological, and other non-germane activities (?“non-chargeable activities?”) which Plaintiff Lautenbaugh and other class members do not support. The NSBA fails to provide constitutionally required procedural protections to safeguard Plaintiff Lautenbaugh?’s and other class members?’ First and Fourteenth Amendment rights. Plaintiff Lautenbaugh therefore seeks injunctive relief to enjoin the NSBA?’s unconstitutional actions.
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