Keller Deduction

Keller Compliance

In the U.S. Supreme Court case Keller v. State Bar of California, the Court ruled that a bar association may not use mandatory member fees to support political or ideological activities that are not reasonably related to the regulation of the legal profession or improving the quality of legal services. If a mandatory bar does engage in such “nonchargeable” (non-germane) activities, the bar is required to identify the license fee cost involved and to establish a system to allow objecting members to either deduct that portion of their fees or receive a refund.

Keller remains the governing standard, and lower courts in recent years have scrutinized and defined germane activities.  WSBA leaders are following the case law closely, and we are committed to the spirit and evolving interpretations of the law: Our licensees can and should expect their fees to be used to regulate the legal profession and/or improve the quality of legal services for Washingtonians. Accordingly, we carefully calibrate our activities and our Keller deduction annually—and that is why the amount varies from year to year.  We include the cost of an activity in the deduction for members if reasonable minds could disagree on whether the activity meets Keller’s germaneness standard, and we fine-tune such activities over time to align with our core, germane functions as a mandatory bar. 

Questions? Email questions@wsba.org.  

Annual Notice to WSBA Members

This year (2027), objecting members may deduct up to the following amounts:

Overview, Calculation and Arbitration

2027 Keller Deduction Memo

Comparison to previous years

2026 Keller Deduction