others that violate legal ethics guidelines, although Justice Thurgood Marshall criticized that approach as benefiting primarily white establishment attorneys who could afford to work without pay, rather than increasing diversity within the bar, as NAACP practices had. Thus, in Ohralik v. Ohio State Bar Assn.,436 U.S. 447 (1978), the Supreme Court distinguished inappropriate for-profit client solicitations from the protected political speech in Button and the ACLU attorney in In re Primus, whom it found South Carolina improperly prosecuted for offering legal services for free to a woman who was involuntarily sterilized. References External links United States Supreme Court cases United States Supreme Court cases of the Warren Court Virginia law 1963 in United States case law United States equal protection case law Void for vagueness case law United States Free Speech Clause case law 1963 in Virginia NAACP Civil rights movement case law