In Board of Regents of Univ. of Wisc. Sys. v. Southworth, 529 U.S. 217, 120 S. Ct. 1346, 1355, 146 L. Ed. 2d 193 (2000), the Court declined to extend the reasoning of Abood v. Detroit Bd. of Educ and Keller v. State Bar of Cal to mandatory student fees that fund ideological student activities at a public university. The Court observed that the standard applied in Abood and Keller, under which dissenting union and bar association members may be required to contribute only "to speech germane to the purposes of the union or bar association," is "difficult to define . . . with ease or precision," and "becomes all the more unmanageable in the public university setting . . . where the State undertakes to stimulate the whole universe of speech and ideas." Id. at 230, 120 S.Ct. at 1355, 146 L.Ed.2d at 207. Accordingly, the Court held that "the First Amendment permits a public university to charge its students an activity fee used to fund extracurricular student speech if the program is viewpoint neutral." Id. at 221, 120 S.Ct. at 1350, 146 L.Ed.2d at 200-01. In a concurring opinion, Justice Souter noted that a student who is compelled to contribute to a student activity fee that is distributed to numerous organizations engaged in a variety of expressive activities has a more attenuated relationship to expressive activity with which the student disagrees than a person who is compelled to pay dues that a union or bar association directly uses to promote its political or ideological agenda: In the union and bar association cases, an individual was required to join or at least drop money in the coffers of the very organization promoting messages subject to objection. The connection between the forced contributor and the ultimate message was as direct as the unmediated contribution to the organization doing the speaking. The student contributor, however, has to fund only a distributing agency having itself no social, political, or ideological character and itself engaging (as all parties agree) in no expression of any distinct message. . . . Thus, the clear connection between fee payer and offensive speech that loomed large in our decisions in the union and bar cases is simply not evident here. Id. at 239, 120 S.Ct. at 1360, 146 L.Ed.2d at 212.