Washington Legal v. Massachusetts Bar

Case Date: 06/04/1993
Court: United States Court of Appeals
Docket No: 92-1775


June 3, 1993 UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________

No. 92-1775

WASHINGTON LEGAL FOUNDATION, ET AL.,
Plaintiffs, Appellants,

v.

MASSACHUSETTS BAR FOUNDATION, ET AL.,
Defendants, Appellees.
____________
ERRATA SHEET
The opinion of this court issued on May 20, 1993, is amended

as follows:

Page 4, lines 5-6 from bottom: Delete 1987 after 11th Cir.
and add (1987) at end of citation: 484 U.S. 917 (1987).

Page 5, line 13: Abbreviate Indiana to Ind.
line 18: Change Assoc. to Ass'n
footnote 1, line 2: Abbreviate Arkansas to Ark.
line 3: Abbreviate Association to Ass'n
line 5: Delete 1984

Page 11, footnote 4, line 9: change and add as follows:
(1st Cir.), cert. denied, 494 U.S. 1082 (1990).
_____ ______

Page 17, line 8: Abbreviate Educational to Educ.
line 9: Abbreviate Foundation to Found.

Page 22, line 18: Delete (1979)

Page 24, line 3: Delete (1979)

Page 36, footnote 15, line 3: add after ...newspaper), cert.
_____
denied, 113 S. Ct. 1067 (1993);
______
line 10: add after ...organizations), cert. denied, 493
_____ ______
U.S. 1094 (1990);
line 11: add after ...NJPIRG), cert. denied, 475 U.S.
_____ ______
1082 (1986);



UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________________
No. 92-1775

WASHINGTON LEGAL FOUNDATION, ET AL.,

Plaintiffs, Appellants,

v.

MASSACHUSETTS BAR FOUNDATION, ET AL.,

Defendants, Appellees.

____________________

APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Joseph L. Tauro, U.S. District Judge]
___________________

____________________

Before

Breyer, Chief Judge,
___________
Bownes, Senior Circuit Judge,
____________________
and Boudin, Circuit Judge.
_____________

____________________

Richard A. Samp, with whom Daniel J. Popeo, John C. Scully, and
_______________ ________________ _______________
Francis C. Newton, Jr. were on brief, for appellants.
______________________
Allan van Gestel, with whom James C. Rehnquist, John C.
__________________ _____________________ ________
Kissinger, Jr., and Goodwin Procter & Hoar were on brief, for
_______________ _________________________
Massachusetts Bar Foundation, William W. Porter, Assistant Attorney
_________________
General, and Scott Harshbarger, Attorney General, on brief for
__________________
Massachusetts IOLTA Committee, Donald K. Stern, S. Tara Miller, and
________________ _______________
Hale and Dorr on brief for Boston Bar Foundation, Joseph L. Kociubes,
_____________ __________________
Stephanie A. Kelly, Diane E. Cooley, and Bingham, Dana & Gould on
__________________ ________________ ______________________
brief for Massachusetts Legal Assistance Corporation, appellees.
William W. Porter, Assistant Attorney General, and Scott
____________________ _____
Harshbarger, Attorney General, on brief for The Chair of the
___________
Massachusetts Board of Bar Overseers, appellee.
William W. Porter, Assistant Attorney General, and Scott
___________________ _____
Harshbarger, Attorney General, on brief for The Justices of the
___________
Massachusetts Supreme Judicial Court, appellees.
Peter M. Siegel, Randall C. Berg, Jr., and Arthur J. England,
________________ ______________________ ___________________
Jr., and Greenberg, Traurig, Hoffman, Lipoff, Rosen & Quentel, P.A. on
___ __________________________________________________________
brief for Alabama Law Foundation, Inc., Alabama State Bar, Arkansas
IOLTA Foundation, State Bar of Arizona, Arizona Bar Foundation, The

State Bar of California, The Legal Services Trust Fund Commission of
the State Bar of California, Colorado Bar Association, Colorado Lawyer
Trust Account Foundation, Connecticut Bar Foundation, Connecticut Bar
Association, Delaware Bar Foundation, Delaware State Bar Association,
The Florida Bar, The Florida Bar Foundation, Georgia Bar Foundation,
State Bar of Georgia, Hawaii Bar Foundation, Hawaii State Bar
Association, Idaho Law Foundation, Inc., Idaho State Bar, Illinois
State Bar Association, Lawyers Trust Fund of Illinois, The Iowa State
Bar Association, Kansas Bar Foundation, Kentucky IOLTA Fund, Louisiana
State Bar Association, Maine Bar Foundation, Maine State Bar
Association, Maryland Legal Services Corporation, Maryland State Bar
Association, Inc., State Bar of Michigan, Michigan State Bar
Foundation, Inc., Minnesota Lawyer Trust Account Board, The Missouri
Bar, Missouri Lawyer Trust Account Foundation, National Association of
IOLTA Programs, Inc., National Legal Aid & Defender Association
(NLADA), Nevada Law Foundation, New Hampshire Bar Association, New
Hampshire Bar Foundation, New Jersey State Bar Association, New Jersey
State Bar Foundation, The IOLTA Fund of the Bar of New Jersey, New
Mexico Bar Foundation, New York State Bar Association, Interest on
Lawyer Account Fund of the State of New York, North Carolina Bar
Association, North Carolina State Bar Plan for Interest on Lawyers'
Trust Accounts, State Bar Association of North Dakota, Ohio Legal
Services Program of the Ohio Public Defender Commission, Oklahoma Bar
Foundation, Inc., Oregon Law Foundation, Oregon State Bar,
Pennsylvania Bar Association, Lawyer Trust Account Board
[Pennsylvania], Philadelphia Bar Association, Rhode Island Bar
Foundation, Seattle-King County Bar Association, South Carolina Bar,
The South Carolina Bar Foundation, South Dakota Bar Foundation,
Tennessee Bar Association, Tennessee Bar Foundation, Texas Equal
Access to Justice Foundation, State Bar of Texas, Utah Bar Foundation,
Utah State Bar, Vermont Bar Association, Vermont Bar Foundation, The
Virginia Bar Association, Virginia Law Foundation, Virginia State Bar,
Washington State Bar Association, Legal Foundation of Washington, West
Virginia Bar Foundation, Inc., West Virginia State Bar, amici curiae.
J. Michael McWilliams, Dennis A. Kaufman, and John H. Morrison on
_____________________ _________________ ________________
brief for The American Bar Association, amicus curiae.
Gerald B. Gallagher, on brief pro se, amicus curiae.
___________________
Kathleen McDonald O'Malley, Chief Counsel, Patrick A. Devine,
____________________________ __________________
Assistant Attorney General, Lee Fisher, Attorney General of Ohio,
___________
Winston Bryant, Attorney General of Arkansas, Richard Blumenthal,
_______________ ___________________
Attorney General of Connecticut, Larry EchoHawk, Attorney General of
______________
Idaho, Roland W. Burris Attorney General of Illinois, Bonnie J.
__________________ _________
Campbell, Attorney General of Iowa, Michael E. Carpenter, Attorney
________ _____________________
General of Maine, J. Joseph Curran, Jr., Attorney General of Maryland,
_____________________
Hubert H. Humphrey, III, Attorney General of Minnesota, Mario J.
_________________________ _________
Palumbo, Attorney General of West Virginia, Mike Moore, Attorney
_______ __________
General of Mississippi, Frankie Sue Del Papa, Attorney General of
______________________
Nevada, Robert J. Del Tufo, Attorney General of New Jersey, Tom Udall,
__________________ _________
Attorney General of New Mexico, Nicholas J. Spaeth, Attorney General
__________________



of North Dakota, Earnest D. Preate, Jr., Attorney General of
__________________________
Pennsylvania, Dan Morales, Attorney General of Texas, Jeffrey L.
____________ ___________
Amestoy, Attorney General of Vermont, Robert Abrams, Attorney General
_______ _____________
of New York, Charles W. Burson, Attorney General of Tennessee, Ken
__________________ ___
Eikenberry, Attorney General of Washington, and Mary Sue Terry,
__________ ________________
Attorney General of Virginia, on brief for the States of Ohio,
Arkansas, Connecticut, Idaho, Illinois, Iowa, Maine, Maryland,
Minnesota, Mississippi, Nevada, New Jersey, New Mexico, New York,
North Dakota, Pennsylvania, Tennessee, Texas, Vermont, Washington,
West Virginia, and Virginia, amici curiae.

____________________

May 20, 1993
____________________





BOWNES, Senior Circuit Judge. This appeal involves
BOWNES, Senior Circuit Judge
____________________

a challenge to the Massachusetts Interest on Lawyers' Trust

Accounts ("IOLTA") program. The district court granted the

defendants' motion to dismiss the plaintiffs' claims that the

IOLTA program violated their First Amendment rights of

freedom of speech and association, and effected a taking of

their property in violation of the Fifth and Fourteenth

Amendments. We affirm.
I.
I.
BACKGROUND
BACKGROUND
__________

Traditionally, in Massachusetts and in other

states, clients' funds which lawyers held for a short term or

in nominal amounts were deposited into non-interest bearing

pooled trust accounts. See, e.g., In Re Mass. Bar Ass'n, 478
___ ____ _____________________

N.E.2d 715, 716 (Mass. 1985); In Re Minn. State Bar Ass'n,
____________________________

332 N.W.2d 151, 155-56 (Minn. 1982). Banking laws and the

ethical obligation of lawyers to maintain clients' funds so

that they were immediately available for reimbursement

prevented such pooled trust accounts from accruing interest.

Cone v. State Bar of Fla., 819 F.2d 1002, 1005 (11th Cir.),
____ __________________

cert. denied, 484 U.S. 917 (1987). Interest earned by pooled
_____ ______

trust accounts remained with the banking institution which

held the funds. Id. With the advent of Negotiable Order of
___

Withdrawal ("NOW") accounts authorized by the Consumer

Checking Account Equity Act, interest became available on

-4-

checking accounts for eligible depositors. Id. at 1005-06.
___

Eligible depositors include individual owners of deposited

funds and certain charitable, non-profit or public interest

entities including IOLTA programs. See id.; In Re N. H. Bar
___ ___ ________________

Ass'n, 453 A.2d 1258, 1259 (N.H. 1982). During the late
_____

1970's and through the 1980's, Florida and many other states

proposed IOLTA programs and courts upheld the programs

finding them constitutionally and ethically permissible.1

As of January, 1992, forty-nine states and the District of

Columbia had authorized IOLTA programs. ABA/BNA Lawyers'

Manual on Professional Conduct 45:202 (1992). Indiana

remains the only state which has not adopted an IOLTA

program. Id.; In Re Public Law No. 154-1990, 561 N.E.2d 791
___ _____________________________

(Ind. 1990); In Re Ind. State Bar, 550 N.E.2d 311 (Ind.
______________________

1990).

The Massachusetts IOLTA program was established by

amendment to Canon 9, DR 9-102 of Rule 3:07 of the Rules of

the Supreme Judicial Court, effective September 1, 1985, the

"IOLTA Rule." Mass. Bar Ass'n, 478 N.E.2d at 720-21. From
_______________

1985 until 1990, the IOLTA program operated as a voluntary

____________________

1 See, e.g., Cone, 819 F.2d 1002; In Re Interest on Trust
___ ____ ____ _______________________
Accounts, 402 So.2d 389 (Fla. 1981); In Re Ark. Bar Ass'n,
________ _____________________
738 S.W.2d 803 (Ark. 1987); Mass. Bar Ass'n, 478 N.E.2d 715;
_______________
Carroll v. State Bar of California, 213 Cal. Rptr. 305 (4th
_______ ________________________
Dist.), cert. denied sub nom. Chapman v. State Bar of Calif.,
_____ ______ ___ ____ _______ ___________________
474 U.S. 848 (1985); In Re Interest on Lawyers' Trust
____________________________________
Accounts, 672 P.2d 406 (Utah 1983); N. H. Bar Ass'n, 453 A.2d
________ _______________
1258; Minn. State Bar Ass'n, 332 N.W.2d 151.
_____________________

-5-

system. Attorneys could elect to participate by establishing

an interest-bearing IOLTA account and by complying with DR 9-

102(C) requirements which included choosing a recipient

charity from a group designated by the IOLTA Committee.

In 1989, the Massachusetts Supreme Judicial Court

("SJC") converted the voluntary IOLTA program into a

mandatory program by amending the IOLTA Rule, effective

January 1, 1990. As amended, the rule required all

Massachusetts lawyers to deposit client funds into interest

bearing accounts: either (1) a pooled IOLTA account if, in

the judgment of the lawyer, the deposits were nominal in

amount or to be held for only a short period of time; or (2)

individual accounts for all other client funds. The Rule

required lawyers or law firms to direct the banks holding

their IOLTA accounts to disburse accrued interest to a

charitable entity selected by the lawyer or firm from a group

designated by the SJC. The designated charities were

Massachusetts Legal Assistance, the Massachusetts Bar

Foundation, and the Boston Bar Foundation.

The SJC again amended the IOLTA Rule, effective

January 1, 1993, to change the process for disbursement of

IOLTA funds.2 The IOLTA Rule now vests responsibility for


____________________

2 The Massachusetts Supreme Judicial Court amended Rule
3:07, DR 9-102(C) by Order 92-18, effective January 1, 1993.
A copy of DR 9-102 and the amendment appear in the appendix
following this opinion.
-6-

disbursement of IOLTA funds in the IOLTA Committee and

eliminates choice by lawyers of recipient eligible charities.

The IOLTA Committee must disburse sixty-seven percent of all

IOLTA funds to Massachusetts Legal Assistance and the

remaining thirty-three percent to "other designated

charitable entities."

The parties have not briefed or argued any issues

in the context of the 1993 amendment to the IOLTA Rule.3

Although the amendment of the IOLTA Rule affects the process

of funds disbursement, the changes are not material to this

decision. None of the parties argued that the lawyers'

choice of recipient charities, as provided by the 1990

version of the IOLTA Rule, was significant. The funds are

still disbursed primarily to Massachusetts Legal Assistance

with the remainder to "other designated eligible charities"

which are still the Massachusetts Bar Foundation and the

Boston Bar Foundation. In addition, the mission of IOLTA

funds remains the same: "The Massachusetts Legal Assistance

Corporation may use IOLTA funds to further its corporate

purpose and other designated charitable entitles [sic] may

use IOLTA funds either for (1) improving the administration

of justice or (2) delivering civil legal services to those

who cannot afford them." Mass. Sup. J. C. R. 3:07, DR 9-


____________________

3 The Massachusetts Attorney General's Office sent this
court a copy of the amendment to DR 9-102(C) by letter dated
February 12, 1993.

-7-

102(C), as amended by Order 92-18, effective Jan. 1, 1993.
__ _______ __

The corporate purpose of the Massachusetts Legal Assistance

Corporation is to

provid[e] financial support for legal
assistance programs that provide
representation to persons financially
unable to afford such assistance in
proceedings or matters other than
criminal proceedings or matters, except
those proceedings or matters in which the
commonwealth is required to provide
representation.

Mass. Gen. L. ch. 221A, 2 (West Supp. 1992).

Unless further designation is necessary for

clarity, we will refer to the currently effective

Massachusetts Supreme Judicial Court Rule 3:07, DR 9-102(C)

as "DR 9-102(C)" or the "IOLTA Rule."
A. The Plaintiffs' Claims
______________________

There are five plaintiffs in this action. The

Washington Legal Foundation ("WLF") is a non-profit, public

interest law and policy center operating in Washington, D.C.

Karen Parker is a citizen of Massachusetts who has employed

lawyers in connection with her real estate business and other

businesses, which has resulted in her money being deposited

in IOLTA accounts. Stephanie Davis is a citizen of

Massachusetts who has not had her money placed in IOLTA

accounts, but she anticipates that, in the future, she may

need to hire an attorney which would cause her money to be

deposited in an IOLTA account. William R. Tuttle is an
-8-

attorney practicing in Abington, Massachusetts, without an

IOLTA account. Timothy J. Howes is an attorney in

Springfield, Massachusetts, where he maintains an IOLTA

account in the Shawmut Bank. Howes is suing on behalf of

himself and on behalf of his clients whose funds are

deposited in his IOLTA account.

The defendants are the Massachusetts Bar

Foundation, the Boston Bar Foundation, the Massachusetts

Legal Assistance Corporation, Katherine S. McHugh (in her

capacity as chair of the Massachusetts IOLTA Committee), Fran

F. Burns (in his capacity as chair of the Board of Bar

Overseers), and the Justices of the Supreme Judicial Court of

Massachusetts. The plaintiffs allege, pursuant to 42 U.S.C.

1983, that they have been deprived, under color of state

law, of their rights secured by the First, Fifth and

Fourteenth Amendments of the Constitution by operation of the

Massachusetts IOLTA program. 1. Count One: First and
_________________________

Fourteenth Amendments
_____________________

WLF alleges that it sent a check to cover costs and

expenses related to this legal action to a Massachusetts

attorney (not a party to the action) who deposited the check

in his IOLTA account as required by the IOLTA Rule. Parker

alleges that she has and will continue to use lawyers in

connection with her real estate business and that her funds

-9-

deposited with lawyers have and will be deposited in IOLTA

accounts. WLF and Parker allege that:

The collection of and use of interest,
under color of state law, generated from
the IOLTA trust account of [their
attorneys] for litigation, especially for
litigation that involves political or
ideological causes, and for legislative
or other forms of lobbying, deprive
[them] of their rights to freedom of
speech and association guaranteed by the
First and Fourteenth Amendments to the
U.S. Constitution.

Davis alleges that although she has not yet had

money deposited in an IOLTA, the IOLTA Rule creates "the risk

that she will be forced to choose between employing an

attorney or financially supporting organizations with which

she disagrees." Davis alleges her constitutional claims in

substantially similar terms to those quoted above. Attorney

Howes alleges that he has had to deposit client funds in his

IOLTA as required by the IOLTA Rule and that the Rule "forces

[him] to choose between not practicing law and or [sic]

practicing law and associating with organizations whose

actions offend his political and ideological beliefs and

thereby depriving him of his right to freedom of speech and

association as guaranteed by the First and Fourteenth

Amendments to the U.S. Constitution." Finally, Attorney

Tuttle alleges that the IOLTA Rule has forced him "to forego,

to his professional and financial detriment, depositing

certain client funds into non-interest bearing accounts in

-10-

order to avoid associating with organizations whose actions

offend his political and ideological beliefs" thereby

depriving him of the same constitutional rights as alleged by

Attorney Howes.

In summary, Count I alleges violation of the

plaintiffs' rights of freedom of speech and association.





-11-

2. Count Two: Fifth and Fourteenth Amendments
___________________________________________

Plaintiffs WLF and Parker allege that the IOLTA

Rule constitutes an illegal taking of the beneficial use of

their funds for public use without just compensation and

without due process of law in violation of the Fifth and

Fourteenth Amendments to the Constitution.4 Howes makes the

same claim on behalf of his clients whose funds he has

deposited into his IOLTA account. Neither Davis, Howes (on

his own behalf) nor Tuttle make claims under Count II.

3. Relief Requested
________________

The plaintiffs ask for declaratory and injunctive

relief to dismantle the operation of the mandatory IOLTA

program. Specifically, the plaintiffs request that the

court: (1) require the defendants to refund the interest

which has been earned on their funds while in IOLTA accounts;

(2) declare the IOLTA Rule void as an unconstitutional

violation of the plaintiffs' First, Fifth and Fourteenth

____________________

4 The plaintiffs have not pursued their claims alleged in
Count III based on the Fourteenth Amendment that the IOLTA
program has unconstitutionally deprived them of their
property without due process of law. The plaintiffs'
statement of issues on appeal is limited to the
constitutional rights of the plaintiffs under the First and
Fifth Amendments. Therefore, we assume that the plaintiffs'
claims under the Fourteenth Amendment have been abandoned and
are waived. United States v. Zannino, 895 F.2d 1, 17 (1st
______________ _______
Cir.) cert. denied, 494 U.S. 1082 (1990). Of course, the
_____ ______
Fourteenth Amendment is properly included in each count as
the basis upon which the First and Fifth Amendment
prohibitions apply to the states.


-12-

Amendment rights; (3) issue permanent injunctions prohibiting

the defendants from requiring attorneys to comply with the

IOLTA Rule and from disciplining attorneys for failure to

comply with the IOLTA Rule; (4) issue a permanent injunction

directing the SJC to require attorneys to make full

disclosure to their clients of uses of IOLTA funds if the

attorney elects to participate in IOLTA, and (5) grant

reasonable attorneys fees to the plaintiffs pursuant to 42

U.S.C. 1988.
B. Dismissal of Claims
___________________

The defendants moved to dismiss the plaintiffs'

action on the grounds that their constitutional claims lacked

merit and that some of the plaintiffs lacked standing.5 The

district court found that there was no serious dispute that

at least two of the plaintiffs, Parker and Howes, had

standing to bring their constitutional claims. The district

court dismissed the plaintiffs' claims holding "that the

plaintiffs have no property interest in the funds subject to

____________________

5 On appeal, the record includes only the defendants' bare
motion to dismiss which states the grounds as lack of subject
matter jurisdiction and failure to state a claim upon which
relief may be granted. The district court summarized the
defendants' grounds for the motion to dismiss: "In addition
to arguing that the plaintiffs' constitutional challenges are
without merit, the defendants contend that two plaintiffs
lack standing." Washington Legal Found., 795 F. Supp. at 52,
_______________________
n.3. We assume, therefore, that the defendants' assertion of
lack of subject matter jurisdiction referred to lack of
standing.

-13-

the SJC Rule," and that the SJC Rule did not compel

association with speech and "speech, in the constitutional

sense, is not a factor of the challenged SJC Rule."

Washington Legal Found., 795 F. Supp. 50, 53, 56 (D. Mass.
________________________

1992). The plaintiffs appeal the district court's dismissal

of their claims.
C. Standard of Review
__________________

Our standard of review of a dismissal pursuant to

Fed. R. Civ. P. 12(b)(6) is well established. We begin by

accepting all well-pleaded facts as true, and we draw all

reasonable inferences in favor of the appellants. Coyne v.
_____

City of Somerville, 972 F.2d 440, 442-43 (1st Cir. 1992).
___________________

Because a dismissal terminates an action at the earliest

stages of litigation without a developed factual basis for

decision, we must carefully balance the rule of simplified

civil pleading against our need for more than conclusory

allegations. Dewey v. University of New Hampshire, 694 F.2d
_____ ___________________________

1, 3 (1st Cir. 1982), cert. denied, 461 U.S. 944 (1983).
_____ ______

Because only well-pleaded facts are taken as true, we will

not accept a complainant's unsupported conclusions or

interpretations of law. United States v. AVX Corp., 962 F.2d
_____________ _________

108, 115 (1st Cir. 1992) ("a reviewing court is obliged

neither to 'credit bald assertions, periphrastic

circumlocutions, unsubstantiated conclusions, or outright

vituperation,'... nor to honor subjective characterizations,
-14-

optimistic predictions, or problematic suppositions."

(citations omitted)). We may affirm the district court's

order on any independently sufficient grounds. Willhauck v.
_________

Halpin, 953 F.2d 689, 704 (1st Cir. 1991).
______

D. Standing
________

The issue of standing has not been raised by the

parties on appeal, and therefore we address standing only

because it presents a threshold jurisdictional question.

Bender v. Williamsport Area School Dist., 475 U.S. 534, 541
______ _______________________________

(1986) ("every federal appellate court has a special

obligation to 'satisfy itself not only of its own

jurisdiction, but also that of the lower courts in a cause

under review,' even though the parties are prepared to

concede it." (citations omitted)); Warth v. Seldin, 422 U.S.
_____ ______

490, 498 (1975) ("[Standing] is the threshold question in

every federal case, determining the power of the court to

entertain the suit."). Standing requirements are most

strictly enforced in cases involving constitutional

questions. Bender, 475 U.S. at 541-42.
______

The standing doctrine is derived from Article III

of the Constitution which requires the existence of a "case

or controversy" before a claim may be resolved by judicial

process. Allen v. Wright, 468 U.S. 737, 750 (1984). To show
_____ ______

a case or controversy, a plaintiff must first "clearly

-15-

demonstrate that he has suffered an 'injury in fact[]'" which

means "an injury to himself that is 'distinct and

palpable,'... as opposed to merely '[a]bstract,' ... and the

alleged harm must be actual or imminent, not 'conjectural' or

hypothetical.'" Whitmore v. Arkansas, 495 U.S. 149, 155
________ ________

(1990) (citations omitted). Second, the claimant must allege

facts which show "that the injury 'fairly can be traced to

the challenged action' and, third, 'is likely to be redressed

by a favorable decision.'" Id. (quoting Simon v. Eastern
___ _____ _______

Kentucky Welfare Rights Organization, 426 U.S. 26, 38, 41
______________________________________

(1976) and Valley Forge Christian College v. Americans United
______________________________ ________________

for Separation of Church and State, Inc., 454 U.S. 464, 472
_________________________________________

(1982); see also Rumford Pharmacy v. City of East Providence,
___ ____ ________________ _______________________

970 F.2d 996, 1001 (1st Cir. 1992); AVX Corp., 962 F.2d at
_________

113. Our standing inquiry depends on whether the plaintiffs

have established the existence of a case or controversy as to

each of their claims, but does not involve the merits of

particular claims. Warth, 422 U.S. at 500.
_____

The district court found that at least Howes and

Parker had standing to bring the constitutional challenges in

this case. Karen Parker alleges that she has and will

continue to employ lawyers for transactions related to her

business and that she has and will have her funds placed in

IOLTA accounts by the lawyers she employs. She claims that

the IOLTA program collects and uses for political and

-16-

ideological causes interest generated by her funds placed in

IOLTA accounts, and therefore the operation of the IOLTA

program deprives her of freedom of speech and association in

violation of the First Amendment. Parker also claims that

the IOLTA program constitutes an illegal taking of the

beneficial use of her funds deposited in IOLTA accounts in

violation of the Fifth Amendment. She asks this court to

declare the IOLTA Rule unconstitutional and to enjoin the

operation of the rule. Based upon her allegations, which we

take as true for this purpose, she has stated an actual

injury to herself which is traceable to the IOLTA rule and

which may be remedied by the relief sought. We agree with

the district court that Parker has standing to maintain her

claims made in this action.

Howes presents a more complex standing situation.

Howes brings the First Amendment claim on his own behalf and

on behalf of his clients, and the Fifth Amendment claim only

on behalf of his clients.6 As to the First Amendment claim


____________________

6 Howes' standing on behalf of third parties is more
difficult. The general rule is that a plaintiff has standing
to assert only his own rights, not those of third parties.
Playboy Enterprises, Inc. v. Public Service Comm'n, 906 F.2d
_________________________ _____________________
25, 36-37 (1st Cir.), cert. denied, sub nom. Rivera Cruz v.
_____ ______ ___ ____ ____________
Playboy Enterprises, Inc., 498 U.S. 959 (1990). An exception
_________________________
to the rule against jus tertii standing exists if other
___ ______
considerations, such as the representative's relationship
with the third party and the opportunity of the third party
to assert its own rights, overcome prudential concerns. Id.
___
at 37. We do not address the third party standing issue,
however, because it is unnecessary for our limited purpose of
determining jurisdiction.

-17-

on his own behalf, Howes alleges that he has been compelled

by the IOLTA Rule to participate in the IOLTA program and

thereby to associate with IOLTA funded organizations which

offend his political and ideological beliefs. Howes also

alleges that the operation of the IOLTA Rule forces him to

choose between practicing law and not practicing law. He

asks for the same relief requested by Parker. Without

addressing the merits of Howes' personal claims, we find that

he has alleged an injury which may be remedied by the

requested relief which is sufficient to establish his

standing to maintain his First Amendment claim.

Because we find that at least two of the

plaintiffs, Parker, a client, and Howes, a lawyer, have

standing to maintain each claim, we need not address the

standing of all plaintiffs as to each claim. Watt v. Energy
____ ______

Action Educ. Found., 454 U.S. 151, 160 (1981); Buckley v.
____________________ _______

Valeo, 424 U.S. 1, 12 (1976) (finding appellants had standing
_____

because "at least some of the appellants have a sufficient

'personal stake' in a determination of the constitutional

validity of each of the challenged provisions to present 'a

real and substantial controversy admitting of specific relief

through a decree of a conclusive character'" (citation and

footnote omitted)). We find, therefore, that based on

Parker's and Howes' standing, we have jurisdiction in this

case.

-18-

II.
II.
ANALYSIS
ANALYSIS
________

The plaintiffs7 allege that the Massachusetts

IOLTA program violates their First Amendment rights by

collecting the interest generated by clients' funds which are

deposited in IOLTA accounts and distributing the money to

designated organizations. The plaintiffs further allege that

the recipient organizations use the money for litigation

involving political or ideological causes and for lobbying.

The IOLTA program, the plaintiffs allege, therefore compels

them to support political and ideological causes depriving

them of freedom of speech and association. The plaintiffs

also allege that the IOLTA program's appropriation of

interest from lawyers' trust accounts takes the beneficial

use of client funds which constitutes an unconstitutional

taking in violation of the Fifth and Fourteenth Amendments.8

A. The Fifth Amendment Taking Claim
________________________________


____________________

7 As noted above, all of the plaintiffs do not join in all
counts of the complaint. In addition, we have not resolved
the standing of all plaintiffs. "Plaintiffs" as used
throughout this opinion will refer to the particular
plaintiffs making the claims discussed without resolving
standing.

8 We address the plaintiffs' Fifth Amendment claim first,
although it is raised in Count II of the plaintiffs'
complaint, in order to resolve the plaintiffs' property
rights to funds deposited in IOLTA accounts before discussing
the First Amendment claim which also involves that issue.

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The Fifth Amendment provides that "private property

[shall not] be taken for public use, without just

compensation." There is no dispute that clients' money or

property held by lawyers belongs to the clients and must be

returned to the clients at their request. Mass. S. J. C.

Rule 3:07, Cannon 9, DR 9-102(B)(4); Mass. Gen. L. Ann. ch.

221, 51 (1986). Many courts, including the Supreme

Judicial Court of Massachusetts, have held that clients do

not have a constitutionally protected property right to the

interest earned on IOLTA accounts.9 Mass. Bar Ass'n, 478
________________

N.E.2d at 718; see also Cone, 819 F.2d at 1007; Carroll, 213
___ ____ ____ _______

Cal. Rptr. at 312; Minn. State Bar Ass'n, 332 N.W.2d at 158;
_____________________

N. H. Bar Ass'n, 453 A.2d at 1260-61. Perhaps in response,
_______________

the plaintiffs have eschewed a right to the interest itself,

and instead claim a property right to the beneficial use of

their deposited funds, and more specifically, the right to

control and to exclude others from the beneficial use of

those funds.

To make a cognizable claim of a taking in violation

of the Fifth Amendment, the plaintiffs must first show that

they possess a recognized property interest which may be

protected by the Fifth Amendment. Penn Cent. Transp. Co. v.
______________________

____________________

9 We accept as true, as do all of the parties, the
assumption that there are no feasible accounting procedures
which would allow individual client funds deposited into
pooled accounts to earn net interest.

-20-

New York City, 438 U.S. 104, 124-25 (1978). The plaintiffs
_____________

must point to credible sources for their claimed property

interest:

Property interests, of course, are not
created by the Constitution. Rather,
they are created and their dimensions are
defined by existing rules or
understandings that stem from an
independent source such as state
law rules or understandings that secure
certain benefits and that support claims
of entitlement to those benefits.

Board of Regents v. Roth, 408 U.S. 564, 577 (1972).
___________________ ____

Intangible property rights, "'the group of rights inhering in

the citizen's relation to the physical thing, as the right to

possess, use and dispose of it[,]'" which are recognized by

state law are protected by the Takings Clause. Ruckelshaus
___________

v. Monsanto Co., 467 U.S. 986, 1003 (1984) (quoting United
_____________ ______

States v. General Motors Corp., 323 U.S. 373, 377-78 (1945));
______ ____________________

see also Bowen v. Gilliard, 483 U.S. 587, 603-09 (1987)
___ ____ _____ ________

(finding no unconstitutional taking of child's right to have

support payments used for child's best interest by an

amendment to the AFDC statute). Not all asserted property

interests are constitutionally protected, however, as "a mere

unilateral expectation or an abstract need is not a property

interest entitled to protection." Webb's Fabulous
_________________

Pharmacies, Inc. v. Beckwith, 449 U.S. 155, 161 (1980).
________________ ________

1. Beneficial Use of Deposited Funds
_________________________________

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The plaintiffs rely on trust law to establish their

right to control the beneficial use of their funds as a

protected property interest. IOLTA deposits do not require a

trust agreement and the plaintiffs have not argued that

formal trust agreements exist. Rather, the plaintiffs

contend that because the acronym "IOLTA" includes the word

"trust," a trust relationship is created between lawyer and

client when client funds are deposited into IOLTA accounts.

The relationship between lawyer and client in Massachusetts

is fiduciary as a matter of law. Markell v. Sidney B.
_______ _________

Pfeifer Found., Inc., 402 N.E.2d 76, 94 (Mass. App. 1980).
_____________________

The lawyer-client relationship presumes that the client

trusts the lawyer to handle the client's funds appropriately

and the lawyer assumes the fiduciary obligation subject to

the regulation of the profession. We are not convinced that

the deposit of clients' funds into IOLTA accounts transforms

a lawyer's fiduciary obligation to clients into a formal

trust with the reserved right by the client to control the

beneficial use of the funds as claimed by the plaintiffs.

The plaintiffs also claim that they have a

protected property right to exclude others from the

beneficial use of their funds while they are deposited in

IOLTA accounts. In support of the right to exclude, the

plaintiffs rely on cases which have established that property

owners have a right to exclude others from their real

-22-

property. See, e.g., Kaiser Aetna v. United States, 444
___ ____ ____________ _____________

U.S. 164, 176; Loretto v. Teleprompter Manhattan CATV Corp.,
_______ _________________________________

458 U.S. 419, 435-36 (1982). The plaintiffs have cited no

sources which recognize a similar constitutionally protected

property right to control or exclude others from intangible

property and we have found none.10



2. IOLTA Program Does Not Cause a Taking
_____________________________________

Assuming arguendo that the plaintiffs could
________

establish their claimed property interests in the beneficial

use of their funds subject to the IOLTA Rule, the IOLTA

program does not cause an illegal taking of those interests.

The analysis of Fifth Amendment takings claims has evolved

through a series of cases in which Supreme Court decisions

"engaging in ... essentially ad hoc, factual inquiries ...

have identified several factors that have particular

significance." Penn Central, 438 U.S. at 124. The Court has
____________

repeatedly used the significant factors enunciated in Penn
____

Central to analyze takings claims: "(1) 'the economic impact
_______

of the regulation on the claimant'; (2) 'the extent to which

____________________

10 The plaintiff has not discussed, and we do not find
analogous, intangible property rights which, by their nature
or by agreement, require the exclusion of others to preserve
the property interest. See, e.g., Monsanto, Co., 467 U.S. at
___ ____ _____________
1002 ("Because of the intangible nature of a trade secret,
the extent of the property right therein is defined by the
extent to which the owner of the secret protects his interest
from disclosure to others.").

-23-

the regulation has interfered with distinct investment-backed

expectations'; and (3) 'the character of the governmental

action.'" Connolly v. Pension Benefit Guaranty Corp., 475
________ ______________________________

U.S. 211, 225 (1986) (citation omitted); see also Hodel v.
___ ____ _____

Irving, 481 U.S. 704, 714-15 (1987); Kaiser, 444 U.S. at 175.
______ ______

The government may impose regulations to adjust rights and

economic interests among people for the public good, as long

as the government does not force "some people alone to bear

public burdens which, in all fairness and justice, should be

borne by the public as a whole." Armstrong v. United States,
_________ _____________

364 U.S. 40, 49 (1960); see also Andrus v. Allard, 444 U.S.
___ ____ ______ ______

51, 65 (1979).

a. Character of governmental action.
_________________________________

The plaintiffs claim that the character of

governmental action, through the IOLTA Rule, is a physical

invasion of their beneficial interests in their funds held in

IOLTA accounts. The physical invasion occurs, the plaintiffs

argue, because the IOLTA program borrows the principal to

generate income by collecting the interest earned on IOLTA

accounts. The plaintiffs do not claim that they have any

rights to the interest, rather they assert the right to

control who uses and benefits from the principal which

generates the interest. The IOLTA program, the plaintiffs

-24-

claim, "involves a permanent physical invasion of the funds"

while they are held in IOLTA accounts.

The Supreme Court has recognized that a taking is

more obvious when the governmental action can be

characterized as a physical invasion. Penn Central, 438 U.S.
____________

at 124. The Court has identified particular governmental

action as categorical or per se takings which generally
___ __

occur: (1) when government action compels property owners to

acquiesce in permanent physical invasion or occupation of

their private property, and (2) when "regulation denies all

economically beneficial or productive use of land." Lucas
_____

v. South Carolina Coastal Council, 112 S. Ct. 2886, 2893
_______________________________

(1992); see also Yee v. City of Escondido, Cal., 112 S. Ct.
___ ____ ___ _______________________

1522, 1526 (1992).

The plaintiffs argue that the IOLTA program causes

a physical taking similar to the takings found in Kaiser, 444
______

U.S. 164 (1979); Loretto, 458 U.S. 419; and Webb's, 449 U.S.
_______ ______

155. In Kaiser, owners of a private marina, who had
______

connected their private pond to the Pacific Ocean, challenged

the federal government's imposition of a navigational

servitude on their property requiring that they allow a right

of access to the public. The Court found that the

government's regulation of the marina amounted to a physical

invasion of their private property by the public, and was,

therefore, an unconstitutional taking of the marina owners'

-25-

right to exclude others from their private property. Kaiser,
______

444 U.S. at 180.

In Loretto, 458 U.S. 419, government regulation
_______

required private property owners to allow conduits for cable

television to be attached to their buildings even when the

property owners did not subscribe to cable television. The

Court found that the regulation authorized a physical

occupation, however small, of the plaintiff's private

property which was unconstitutional without compensation.

We find no logical analogy between the physical

invasion of real property, as in Kaiser and Loretto, and the
______ _______

operation of the IOLTA Rule. The plaintiffs' takings claim

involves intangible property rights not real property. To

bolster their claim of physical invasion, the plaintiffs

contend that their property rights are nearly identical to

the claimants' property rights in Webb's, 449 U.S. 155, in
______

which the Court stated "the [government's] appropriation of

the beneficial use of the fund is analogous to the

appropriation of the use of private property." Id. a