See Bureau of Labor Statistics, available at http://www.bls.gov/news.release/union2.nr0.htm.
 See generally, Staff Rep., H. Comm. on Oversight & Gov. Reform, President Obama’s Pro-Union Board: The NLRB’s Metamorphosis from Independent Regulator to Dysfunctional Union Advocate (2012), available at http://oversight.house.gov/wp-content/uploads/2012/12/NLRB-Report-FINAL-12.13.12.pdf; Raymond J. LaJeunesse, Union Organizing and the NLRB Under President Obama, Federalist Society (Feb. 6, 2013), http://www.fed-soc.org/publications/detail/union-organizing-and-the-nlrb-under-president-obama.
 Squire Sanders, Management, Buckle Up: It’s Going to Be a Roller Coaster Over the Next Four Years. A Review of the NLRB’s Holiday Gift to Unions and Employees 1–2 (Jan. 2013), available at http://www.squiresanders.com/files/Publication/dd3e29c0-65b9-42b5-b94b-
 Notification of Employees Rights Under the National Labor Relations Act, 76 Fed. Reg. 54,006 (Aug. 30, 2011) (codified at 29 CFR pt. 104).
 Representation—Case Procedures, 76 Fed. Reg. 36812 (June 22, 2011) (codified at 29 CFR pts. 101, 102, and 103); Coalition for a Democratic Workplace, Congressional Review Act and NLRB’s Ambush Election Rule, available at http://myprivateballot.com/wp-content/uploads/2012/02/Fact-Sheet-Congressional-Review-Act-and-Ambush-Election-.pdf.
 In 2012, a federal district court in the District of Columbia struck down the “ambush” election rule because the NLRB did not have a quorum necessary to enact the new rule. Chamber of Commerce v. NLRB, No. 12-5250 (D.C. Cir. 2013). The “ambush” case is now on appeal with the Court of Appeals for the D.C. Circuit. See Coalition for a Democratic Workplace, Congressional Review, supra note 5. On May 7, 2013, the U.S. Court of Appeals for the D.C. Circuit ruled that the entire “poster rule” was invalid because its enforcement mechanisms violated the NLRA. Nat’l Ass’n of Mfrs. v. NLRB, 717 F.3d 947 (D.C. Cir. 2013).
 See National Labor Relations Board (Region 2) decision in Case No. 02-RC-076954, available at http://www.scribd.com/doc/94245228/NLRB-Region-Issues-Micro-Union-Decision-in-Bergdorf-Goodman; Divide, Conquer & Destroy: NLRB Region Unleashes Micro-Unit On Retailer, available at http://laborunionreport.com/2012/05/divide-conquer-destroy-nlrb-region-unleashes-micro-unit-on-retailer/.
 Labor–Management Reporting and Disclosure Act; Interpretation of the “Advice” Exemption, 76 Fed. Reg. 36178 (June 21, 2011) (to be codified at 29 C.F.R. pts. 405 and 406).
 See Ben James, Unions May Look to NLRB If EFCA Fails to Pass, Law360 (July 31, 2009, 1:43 PM), http://www.law360.com/articles/107126/unions-may-look-to-nlrb-if-efca-fails-to-pass; Richard A. Epstein, One Bridge Too Far: Why the Employee Free Choice Act Has, and Should, Fail 1 (John M. Olin Law & Economics, Working Paper No. 528, 2010), available at http://www.law.uchicago.edu/files/file/528-rae-free-choice.pdf.
 Labor–Management Reporting and Disclosure Act of 1959, Pub. L. 86-257, 73 Stat. 519 (codified as amended at 29 U.S.C. §§ 401–531 (2012)). Federal regulations implementing the LMRDA are found in Chapter IV of Title 29 of the Code of Federal Regulations.
 29 C.F.R. pts. 405 and 406 (implementing 29 U.S.C. § 433(b) (2012)). It is worth noting that employers are free to express their views about unions to their employees. Section 8(c) of the National Labor Relations Act, codified at 29 U.S.C. § 158(c), provides: “The expressing of any views, argument, or opinion, or the dissemination thereof, whether in written, printed, graphic, or visual form, shall not constitute or be evidence of an unfair labor practice under any of the provisions of this subchapter, if such expression contains no threat of reprisal or force or promise of benefit.” The Supreme Court recently reaffirmed in Chamber of Commerce v. Brown, 554 U.S. 60, 67–68 (2008), that Section 8(c) expresses a congressional policy of “favoring uninhibited, robust, and wide-open debate” on matters relating to unionization so long as that does not include unlawful speech or conduct.
 76 Fed. Reg., at 36186–87.
 See, e.g., Int’l Union, United Auto Workers v. Dole, 869 F.2d 616, 618 (D.C. Cir. 1989) (“Congress intended to grant a broad scope to the term ‘advice.’” (citing H.R. Rep. No. 1147 (1959) (Conf. Rep.), reprinted in 1959 U.S.C.C.A.N. 2503, 2505)).
 See Price v. Wirtz, 412 F.2d 647, 654 (5th Cir. 1969) (Dyer, J., dissenting); Letter from the American Bar Association to Andrew R. Davis, Chief of the Division of Interpretation & Standards, Office of Labor–Management Standards, U.S. Department of Labor, at 2 (Sept. 21, 2011), available at http://www.americanbar.org/content/dam/aba/uncategorized/2011/2011sep21_dolpersuaderrule_c.authcheckdam.pdf.
 A lawyer and managing partner of a law firm that provides persuader advice can face up to a year in jail and a $10,000 penalty for failure to file the required forms or for filing them incorrectly. 29 U.S.C. § 439.
 See, e.g., James Sherk, Unions Use Corporate Campaigns to Circumvent Employees’ Right to Vote, Heritage Foundation WebMemo No. 1418 (Apr. 9, 2007), http://www.heritage.org/research/reports/2007/04/unions-use-corporate-campaigns-to-circumvent-employees-right-to-vote; Carl Horowitz, Wrecking Sodexo: Another Union “Corporate Campaign,” Townhall (July 30, 2011), http://townhall.com/columnists/carlhorowitz/2011/07/30/wrecking_sodexo__another_union_corporate_campaign/page/full. See generally Jarol B. Manheim, The Death of a Thousand Cuts: Corporate Campaigns and the Attack on the Corporation (2001); David A. Bego, The Devil at Our Doorstep (2012).
 See Diana Furchtgott-Roth, The High Costs of Proposed New Labor-Law Regulations, Manhattan Institute (April 2013), available at http://www.manhattan-institute.org/html/ib_21.htm#.Ue7VL22wXjY.
 See, e.g., S. Rep. No. 86-187 (1959), reprinted in 1959 U.S.C.C.A.N. 2318, 2318–27. The evidence of misconduct focused largely on the activities of Nathan Shefferman and his consulting firm, Labor Relations Associates of Chicago, Inc.
 Codified at 29 U.S.C. § 433(b).
 29 C.F.R. § 406.2 (LM-20 30-day Report); 29 C.F.R. § 406.3 (LM-21 Receipts Report).
 29 C.F.R. § 405.2–405.3 (employer annual report).
 See U.S. Dep’t of Labor, Instructions for Form LM-20 Agreement and Activities Report, available at http://www.dol.gov/olms/regs/compliance/GPEA_Forms/lm-20_Instructions.pdf; U.S. Dep’t of Labor, Form LM-20 Agreement and Activities Report, available at http://www.dol.gov/olms/regs/compliance/GPEA_Forms/lm-20p.pdf; U.S. Dep’t of Labor, Instructions for Form LM-21 Receipts and Disbursements Report, available at http://www.dol.gov/olms/regs/compliance/GPEA_Forms/lm-21_Instructions.pdf; U.S. Dep’t of Labor, Form LM-21 Receipts and Disbursements Report, available at http://www.dol.gov/olms/regs/compliance/GPEA_Forms/lm-21p.pdf.
 S. Rep. No. 187 (1959), 1959 WL 3884, reprinted in 1959 U.S.C.C.A.N. 2318, 2356.
 29 U.S.C. § 433(c).
 29 U.S.C. § 434.
 Labor-Management Reporting and Disclosure Act; Interpretation of the “Advice” Exemption; Proposed Rule, Lab. Relations Rep. (CCH) ¶ 9303 (June 22, 2011), 2011 WL 2662304.
 76 Fed. Reg. 36178, at 36180.
 Id. at 36181.
 Id. at 36180.
 See, e.g., Int’l Union, United Auto Workers v. Dole, 869 F.2d 616 (D.C. Cir. 1989).
 76 Fed. Reg. 36178. After the Labor Department issued its Notice of Proposed Rulemaking, it received over 6,000 comments from law firms, associations representing attorneys, companies, and other interested parties, and not a single company or business group supported the rule. Michael Lotito, New Labor Secretary Must Withdraw the Persuader Rule, Law360 (May 31, 2013, 12:24 PM), http://www.law360.com/articles/445452/new-labor-secretary-must-withdraw-the-persuader-rule.
 76 Fed. Reg 36182.
 For an analysis of DOL’s stated justifications for the proposed persuader rule, as well as a rebuttal of those arguments, see Letter from Bradford L. Livingston, Chair of the Labor and Employment Division of Seyfarth Shaw, LLP, to Andrew R. Davis, Chief of the Division of Interpretation & Standards, Office of Labor–Management Standards, U.S. Department of Labor (Sept. 20, 2011) (on file with author); Letter from Society for Human Resource Management to Andrew R. Davis, Chief of the Division of Interpretation & Standards, Office of Labor–Management Standards, U.S. Department of Labor (Sept. 21, 2011), available at http://www.scribd.com/doc/66333026/DOL-Comments-SHRM-Comments-On-The-DOL-s-Proposed-Persuader-Rule.
 76 Fed. Reg. 36182. (emphasis added).
 Id. (emphasis added).
 When a court reviews an agency’s construction of a statute that the agency is charged with administering, the court first looks at the statutory text to see “whether Congress has spoken directly to the question at hand,” and “[i]f the intent of Congress is clear, that is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress.” Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842–43 (1984).
 S. Rep. No. 187 (1959), reprinted in 1959 U.S.C.C.A.N. 2318, 2318, 2323, 2326–28, 2356, 2388; id. at 2326 (The LMRDA was designed to target “middlemen flitting about the country” in order to “work directly on employees or through committees to discourage legitimate organizational drives or set up company-dominated unions [and] negotiate sweetheart contracts.”).
 See Donovan v. Rose Law Firm, 768 F.2d 964, 970–71 (8th Cir. 1985) (“Since attorneys at law…do not themselves engage in influencing or affecting employees in the exercise of their rights under the National Labor Relations Act, an attorney…who confined himself to giving advice [would not] be required to report.” (citing S. Rep. No. 1684 (1958), Leg. Hist. (Labor) at 390)); Wirtz v. Fowler, 372 F.2d 315, 330 (5th Cir. 1966) (citing legislative history and stating that “[g]enerally it was felt that the giving of legal advice to employers was something inherently different from the exertion of persuasion on employees….”).
 Interpretation of “Advice” Exemption, 76 Fed. Reg. at 36192. Indeed, as discussed later in this paper, in enacting the LMRDA, Congress envisioned protecting confidential communications made in the course of a legitimate attorney–client relationship, not just the more narrow subset of communications recognized and protected by the attorney–client privilege. But see Humphreys, Hutcheson and Moseley v. Donovan, 755 F.2d 1211, 1216 (6th Cir. 1985) (“Appellant contends that the attorney–client privilege codified in LMRDA section 204 is broader than the traditional attorney–client privilege. We find to the contrary, that in section 204 Congress intended to accord the same privilege as that provided by the common-law attorney–client privilege.”).
 89 F. Supp. 357, 359 (D. Mass. 1950). United Shoe is cited as a leading opinion in Attorney–Corporate Client Privilege, § 3:28, at 201 (John W. Gergacz, ed., 3d ed. 2011).
 Resident Councils of Wash. v. Leavitt, 500 F.3d 1025, 130 (9th Cir. 2007) (quoting Chevron, 467 U.S. at 842–43).
 Astoria Fed. Savings & Loan Ass’n v. Solimino, 501 U.S. 104, 112 (1991); see also Bailey v. United States, 516 U.S. 137, 146 (1995) (“We assume that Congress used two terms because it intended each term to have a particular, nonsuperfluous meaning.”).
 See 76 Fed. Reg. at 36191 (describing reportable activity under the proposed reinterpretation as “a lawyer or labor consultant [who] has gone beyond mere recommendation and has engaged in actions, conduct, or communications with the object to persuade employees, either directly or indirectly, about the employees’ protected, concerted activity” and noting that “these activities, whether or not the consultant is in direct contact with the employees, trigger the duty to report.” (emphasis added)); see also Mary Swanton, DOL Proposal Could Force Choice Between Confidentiality and Compliance, Inside Counsel (July1, 2013), http://www.insidecounsel.com/2013/07/01/dol-proposal-could-force-choice-between-confidenti?t=labor-employment&page=2; Michael Lotito, New Labor Secretary Must Withdraw the Persuader Rule, Law360 (May 31, 2013, 12:24 PM), http://www.law360.com/articles/445452/new-labor-secretary-must-withdraw-the-persuader-rule.
 76 Fed. Reg. at 36196.
 Staff Rep., H. Comm. on Oversight & Gov. Reform, Continuing Oversight of Regulatory Impediments to Job Creation: Job Creators Still Buried by Red Tape (2012), at 2, 51, available at http://oversight.house.gov/wp-content/uploads/2012/07/Staff-Report-FINAL.pdf.
 Diana Furchtgott-Roth, New Labor Rule Will Violate Attorney–Client Privilege, Wash. Examiner (Apr. 16, 2013, 2:45 PM), available at http://washingtonexaminer.com/diana-furchtgott-roth-new-labor-rule-will-violate-attorney-client-privilege/article/2527314?custom_click=rss.
 See, e.g., Police Dept. of City of Chicago v. Mosely, 408 U.S. 92, 95–96 (1972) (striking down a city ordinance that prohibited picketing within 150 feet of a secondary school, except for labor picketing; “[A]bove all else, the First Amendment means that government has no power to restrict expression because of its message, its ideas, its subject matter, or its content…. The essence of this forbidden censorship is content control.”); Good News Club, v. Milford Central School, 533 U.S. 98 (2001) (holding it unconstitutional to deny use of school property to a religious group while permitting use by other community groups).
 See James Sherk and Ryan O’Donnell, EFCA: High-Pressure Spin Selling and Creative Organizing for Labor Unions, Heritage Foundation WebMemo No. 2335 (March 11, 2009), available at http://www.heritage.org/research/reports/2009/03/efca-high-pressure-spin-selling-and-creative-organizing-for-labor-unions; Strengthening America’s Middle Class Through the Employee Free Choice Act: Hearing Before the Subcomm. on Health, Employment, Labor and Pensions of the H. Comm. on Education and Labor, 110th Cong. (2007) (statement of Jen Jason), available at http://www.gpo.gov/fdsys/pkg/CHRG-110hhrg32906/html/CHRG-110hhrg32906.htm.
 Hunt v. Blackburn, 128 U.S. 464, 470 (1888); see also United States v. Louisville & N.R. Co, 236 U.S. 318, 336 (1915) (“The desirability of protecting confidential communications between attorney and client as a matter of public policy is too well known and has been too often recognized by textbooks and courts to need extended comment now. If such communications were required to be made the subject of examination and publication, such enactment would be a practical prohibition upon professional advice and assistance.”); Upjohn Co. v. United States, 449 U.S. 383, 389 (1981) (noting that the attorney–client privilege serves to “encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice”).
 These reports require that the employer disclose the identity of corporate clients, the nature of the representation, the types of legal tasks performed, all receipts of any kind received from all employer clients “on account of labor relations advice or services,” and all disbursements made in connection with such services (not just those receipts and disbursements that are related to persuader activities).
 Sections 10 and 11 of the proposed new LM-20 form require attorneys to disclose, in written detail and by categories, a large amount of private information about the attorney’s representation of his or her employer client. 76 Fed. Reg. at 36207–15, available at http://www.gpo.gov/fdsys/pkg/FR-2011-06-21/pdf/2011-14357.pdf; see also 76 Fed. Reg. at 36216–26 (Employer LM-10 form requires even more detailed disclosure). Though the agency does not ask for the actual words of the confidential communications in form LM-20, it does require disclosure of confidential information discussed in those communications, which essentially exposes the communication itself and undermines the confidential nature of the attorney–client relationship.
 Such advice might include matters related to Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Occupational Safety and Health Act, the Family and Medical Leave Act, the Employee Retirement Income Security Act, and related state laws.
 Persuader activity, under the proposed interpretation, is defined as “a consultant’s providing material or communications to, or engaging in other actions, conduct, or communications on behalf of an employer that, in whole or in part, have the object directly or indirectly to persuade employees concerning their rights to organize or bargain collectively.” 76 Fed. Reg. at 36182.
 76 Fed. Reg. at 36192; see also Humphreys, Hutcheson and Moseley, 755 F.2d at 1219.
 State Adoption of the ABA Model Rules of Professional Conduct and Comments, ABA (May 23, 2011), http://www.americanbar.org/content/dam/aba/migrated/cpr/pic/comments.authcheckdam.pdf. See generally Peter A. Joy, Making Ethics Opinions Meaningful: Toward More Effective Regulation of Lawyers’ Conduct, 15 Geo. J. Legal Ethics 313 (2002).
 See the ABA Model Rule of Professional Conduct Rule 1.6 and the related commentary, available at http://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information.html.
 State Adoption of the ABA Model Rules of Professional Conduct and Comments, ABA (May 23, 2011), http://www.americanbar.org/content/dam/aba/migrated/cpr/pic/comments.authcheckdam.pdf; Charts Comparing Individual Professional Conduct Rules as Adopted or Proposed by States to ABA Model Rules, ABA, http://www.americanbar.org/groups/professional_responsibility/policy.html; see, e.g., Alabama Ethics Op. 89-111 (1989) (lawyer may not disclose name of client to funding agency); Texas Ethics Op. 479 (1991) (law firm that obtained bank loan secured by firm’s accounts receivable may not tell bank who firm’s clients are and how much each owes); South Carolina Ethics Op. 90-14 (1990) (lawyer may not volunteer identity of client to third party); Virginia Ethics Op. 1300 (1989) (in absence of client consent, nonprofit legal services corporation may not comply with federal agency’s request for names and addresses of parties adverse to certain former clients, since that may involve disclosure of clients’ identities, which may constitute secret). The only state that has not adopted MRPC 1.6 is California, which has an even stricter rule, Business and Professions Code Section 6068(f), which states: “It is the duty of an attorney…to maintain inviolate the confidence and at every peril to himself or herself to preserve the secrets of his or her client.”
 See Model Rules of Prof’l Conduct R.1.6(b)(6)(2013) (“A lawyer may reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary…to comply with other law or a court order”).
 Model Rules of Prof’l Conduct R. 1.6 cmt. 12 (2013). The comment goes on to explain: “When disclosure of information relating to the representation appears to be required by other law, the lawyer must discuss the matter with the client to the extent required by Rule 1.4. If, however, the other law supersedes this Rule and requires disclosure, paragraph (b)(6) permits the lawyer to make such disclosures as are necessary to comply with the law.” The ABA has experienced a long history of debate about whether attorneys are exempt from generally applicable disclosure laws in light of their ethical obligation to maintain their clients’ confidentiality. See Rebecca Aviel, The Boundary Claim’s Caveat: Lawyers and Confidentiality Exceptionalism, 86 Tul. L. Rev. 1055, 1055, 1064–87 (2012) (describing the history of the bar’s “unwilling[ness] to acknowledge that lawyers must comply with laws that require the disclosure of client confidences”). There are no known court cases clarifying this debate, and only recently has academic scholarship picked up the topic. Rebecca Aviel, When the State Demands Disclosure, 33 Cardozo L. Rev. 675, 679 (2011).
 Aviel, The Boundary Claim’s Caveat: Lawyers and Confidentiality Exceptionalism, at 1084–85 & n.121 (citing ABA, Disclosure: Required by Law or Court Order, in ABA/BNA Lawyers’ Manual on Professional Conduct 55:1201 (Supp. 2006)). For example, several state bar associations have concluded that an attorney should resist revealing the existence of a client relationship, the identity of the client, the nature of the representation, and the fees paid on an IRS Form 8300 even though Section 6050I of the IRS code requires that any person engaged in a trade or business who receives cash in excess of $10,000 in a single transaction or related transactions must complete such a form. See, e.g., Massachusetts Bar Association, Ethics Op. 94-7 (1994); Florida Bar Association, Ethics Op. 92-5 (1993); Washington State Bar Association, Ethics Op. 194 (1997); District of Columbia Bar Association, Ethics Op. 214 (1990).
 Because the failure to file persuader reports invokes potential criminal sanctions, the DOL’s proposed change to the advice exemption may also be unconstitutional under the Fifth Amendment’s due process clause because of the vagueness of its parameters. See Kolender v. Lawson, 461 U.S. 352, 357 (1983) (regulations with criminal sanctions “must define the criminal offense with sufficient definiteness that ordinary people can understand what conduct is prohibited and in a manner that does not encourage arbitrary and discriminatory enforcement”); Forbes v. Napolitano, 236 F.3d 1009, 1011 (9th Cir. 2000) (“If a statute subjects transgressors to criminal penalties…vagueness review is even more exacting”); Chatin v. Coombe, 186 F.3d 82, 86-87 (2d Cir. 1999) (scrutinizing a regulation “closely” because its penalties were more like criminal penalties); Grayned v. City of Rockford, 408 U.S. 104, 108 (1972) (regulations must “clearly define” all prohibited acts such that the regulated class is given “fair notice that [its] contemplated conduct is forbidden”).
 See, e.g., Gibson v. Fla. Legislative Investigation Comm’n, 372 U.S. 539 (1963); Louisiana v. NAACP, 366 U.S. 293 (1961); Bates v. Little Rock, 361 U.S. 516 (1960); NAACP v. Alabama ex rel. Patterson, 357 U.S. 449 (1958).
 Buckley v. Valeo, 424 U.S. 1, 64 (1976), superseded by statute on other grounds, Bipartisan Campaign Reform Act of 2002 (BCRA, McCain–Feingold Act), Pub. L. 107–155, 116 Stat. 81 (2002).
 Davis v. Fed. Election Comm’n, 554 U.S. 724, 744 (2008); Buckley, 424 U.S. at 64. Exacting scrutiny is necessary even if a deterrent effect on the exercise of First Amendment rights occurs not from direct government action but from indirect, unintended causes that are the inevitable result of the government’s act of compelling disclosure. Buckley, 424 U.S. at 65.
 Gibson, 372 U.S. at 546.
 Buckley, 424 U.S. at 64.
 Id. at 66; see also Cal. Med. Ass’n v. FEC, 453 U.S. 182 (1981); United States v. Harriss, 347 U.S. 612 (1954).
 Buckley, 424 U.S. at 68; see also Minn. Citizens Concerned for Life, Inc. v. Swanson, 692 F.3d 864, 876 (8th Cir. 2012); Humphreys, Hutcheson and Moseley, 755 F.2d at 1221 (“[W]e must look further to determine whether this disclosure legislation is narrowly tailored to serve a compelling governmental interest….”). Though there are not many cases dealing with compelled disclosure of financial information (most deal with compelled disclosure in the realm of political speech and association, e.g., McIntyre v. Ohio Elections Comm’n, 514 U.S. 334 (1995)), the disclosure of financial details has been treated as interchangeable with the disclosure of member names of organizations. Buckley, 424 U.S. at 66 (“The invasion of privacy of belief may be as great when the information sought concerns the giving and spending of money as when it concerns the joining of organizations, for ‘[f]inancial transactions can reveal much about a person’s activities, associations, and beliefs.’” (citation omitted)); see also Bates v. City of Little Rock, 361 U.S. 516, 518 (1960) (reversing convictions for failing to comply with a city ordinance that required disclosures of “dues, assessments, and contributions paid, by whom and when paid.”).
 76 Fed. Reg. at 36182.
 While one appellate court has held that the government cannot compel a firm to disclose its services to non-persuader clients (see Rose Law Firm, 768 F.2d at 975, in which the court stated that it is “extraordinarily unlikely that Congress intended to require the content of reports by persuaders under § 203(b) and (c) to be so broad as to encompass dealings with employers who are not required to make any report whatsoever under § 203(a)(4).”), four others have decided otherwise. See Humphreys, Hutcheson and Moseley, 755 F.2d at 1222; Master Printers Ass’n v. Donovan, 699 F.2d 370 (7th Cir. 1983); Douglas v. Wirtz, 353 F.2d 30 (4th Cir. 1965); Price v. Wirtz, 412 F.2d 647 (5th Cir. 1969).
 Denius v. Dunlap, 209 F.3d 944, 953–954 (7th Cir. 2000). The First Amendment, rather than the Sixth Amendment, is applicable in the present case because there is no “right to counsel” under the Sixth Amendment for civil matters. (“[A]n individual enjoys no protection provided by the Sixth Amendment until the instigation of criminal proceedings against him.”); see also McNeil v. Wisconsin, 501 U.S. 171, 175 (1991).
 Denius, 209 F.3d at 953–54; see also DeLoach v. Bevers, 922 F.2d 618, 620 (10th Cir. 1990) (“The right to retain and consult an attorney…implicates not only the Sixth Amendment but also clearly established First Amendment rights of association and free speech.”); Martin v. Lauer, 686 F.2d 24, 32 (D.C. Cir. 1982).
 Denius, 209 F.3d at 954; see also Bates v. State Bar of Ariz., 433 U.S. 350, 376 n.32 (1977); Brotherhood of R.R. Trainmen v. Virginia ex rel. Va. State Bar, 377 U.S. 1, 7 (1979) (“A State could not…infringe in any way the right of individuals and the public to be fairly represented in lawsuits….”). The right to obtain legal advice does not depend on the purpose for which the advice is sought, and the right applies equally to legal representation intended to advocate a political or social belief. See NAACP v. Button, 371 U.S. 415, 419–20 (1963).
 Denius, 209 F.3d at 954.