Forced to join the state bar association in order to practice law when he moved to Wisconsin, Schuyler File sued in Milwaukee alleging the Wisconsin Supreme Court’s mandatory membership rule violated his First Amendment rights under the U.S. Constitution. Assigned to Judge Lynn Adelman, the lawsuit was based on the Supreme Court’s 5-4 decision in Janus v. American Federation of State, County & Municipal Employees, 138 S. Ct. 2448 (2018) (overruling Abood v. Detroit Board of Education, 431 U.S. 209 (1977)), which Adelman mentioned in his controversial critique of the high court — The Roberts Court’s Assault on Democracy, 14 Harvard Law & Policy Review 131 (2019).