the dissenters thought that the "normal" attorney-client relationship was often not present in the NAACP's relationships with its legal clients. The dissenters thought the NAACP had violated not only the five new legal business laws, but also similar laws adopted more than 20 years earlier. Harlan noted that the Virginia Supreme Court of Appeals construed the five new legal business laws as not prohibiting the constitutional exercise of freedom of speech and freedom of assembly, and thought that should be determinative. The dissenters denied that litigation enjoyed strong constitutional protection, because it was only "associated" with freedom of expression, and the Virginia statutes only incidentally infringed on this speech. Furthermore, Harlan considered litigation conduct, which does not enjoy the same strong constitutional protection as speech. Harlan also disagreed with the majority's characterization of the NAACP's activities as free from financial gain, calling it not a typical (and protected) attorney-client relationship because the NAACP and its clients lacked enough common interests to avoid maliciousness. The dissenters argued that the Court had never allowed before allowed constitutional lawsuits avoid the rules of evidence, regulation of the law, legal ethics, or other state interests. Harlan chided the majority for labeling the Virginia statutes vague and overbroad, arguing that neither the trial record nor the state courts' construction of the statutes had found the laws vague. Since Harlan would have upheld the statutes despite the First Amendment challenges, he thought the Fourteenth Amendment guarantees of due process of law and equal protection of the law not infringed. Consequences The next year, the Supreme Court heard and decided Brotherhood of Railroad Trainmen v. Virginia ex rel. Virginia State Bar. Virginia's attempt to use its professional responsibility regulations to curtail union practices was again curtailed in another opinion authored by Justice Black, over the dissents of Justices Clark and Harlan. Justice Stewart did not participate in the Trainmen decision. The NAACP v. Button decision, which approved the NAACP's "test case" strategy, also led to the growth of public interest law firms with other goals, such as less restrictive housing of the mentally ill, and even contesting the No Child Left Behind Act. However, those later class action cases also raised possible ethical problems of lawyers placing ideological motivations above actual client interests. The American Bar Association later adopted Model Rule of Professional Conduct 6.1 (applicable to lawyers working without charging clients) to distinguish those solicitations from