The U.S. Court of Appeals for the Sixth Circuit on Thursday joined a number of sister circuits recently in rejecting a constitutional attack on mandatory bar membership, this time in Michigan, and placing the reason at the door of the U.S. Supreme Court.

"Our cases are clear that we may not disregard Supreme Court precedent unless and until it has been overruled by the Court itself," Judge Karen Nelson Moore wrote for a unanimous panel in Taylor v. Buchanan. "Even where intervening Supreme Court decisions have undermined the reasoning of an earlier decision, we must continue to follow the earlier case if it 'directly controls' until the Court has overruled it."