As a touchstone, Abood reached back to James Madison’s rhetorical question ‘who does not see . . . that the same authority which can force a citizen to contribute three pence only of his property for the support of any one establishment, may force him to conform to any other establishment in all cases whatsoever?’ U.S. Supreme Court
431 U.S. at 234,35 n.31 (quoting 2 The Writings of James Madison 186 (Hunt ed. 1901))