Sampson v. Buescher, 625 F.3d 1247

Colorado requires ballot-issue committees to register and disclose contributors and expenditures if they surpass $200, with separate accounts and public reporting.
No Annexation committee Parker North opposed annexation into Parker, Colorado, and raised under $1,000, including in-kind contributions and attorney fees.
Plaintiffs engaged in opposition activities (signs, flyers, letters, internet discussions) and registered an issue committee after learning of the rules.
County and state officials issued subpoenas; ALJ partially granted the subpoena and the matter proceeded to settlement in the administrative process.
Plaintiffs filed § 1983 suit challenging the as-applied burden on the First Amendment right to association and the private-enforcement mechanism.
District court ruled the disclosure requirements applied post-notice date and were facially constitutional; on appeal, the panel held the requirements burdened association and reversed for judgment in plaintiffs’ favor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Colorado’s ballot-issue disclosure burdens violate association rights as applied	Sampson argues the burdens violate First Amendment rights.	Coffman contends the disclosures serve important interests and are constitutionally permissible.	Unconstitutional as applied
Whether the public interest in disclosure justifies the burden on association	Public interest in disclosure is minimal given small expenditures.	Disclosure aids in detecting violations and informs voters.	Insufficient public interest to justify the burden

Buckley v. Valeo, 424 U.S. 1 (U.S. 1976) (disclosure's informational and anti-corruption rationale; limits on candidate contributions)
Bellotti v. Massachusetts, 435 U.S. 765 (U.S. 1978) (authorizes disclosure to inform voters about source of advocacy; involvement of corporations)
City of Berkeley v. Brennan Center, 454 U.S. 290 (U.S. 1981) (contribution caps invalid when disclosure suffices; disclosure as alternative)
Citizens United v. FEC, 130 S. Ct. 876 (U.S. 2010) (recognizes speech and burdens of campaign-finance laws; cautions about complexity and chilling effects)
Doe v. Reed, 130 S. Ct. 2811 (U.S. 2010) (requires substantial relation between disclosure and public interest; anonymity considerations)
McIntyre v. Ohio Elections Comm'n, 514 U.S. 334 (U.S. 1995) (distinguishes disclosure in ballot-issue vs candidate elections; protection of anonymity)
Canyon Ferry Baptist Church v. Unsworth, 556 F.3d 1021 (9th Cir. 2009) (low-value expenditures strengthen argument against disclosure burdens lo lower information yield)
California Pro-Life Council, Inc. v. Getman, 328 F.3d 1088 (9th Cir. 2003) (context for evaluating state interest in ballot-issue disclosure)