Unite for Colorado, Petitioner: v. Colorado Department of State; Jena Griswold, in her official capacity as the Colorado Secretary of State; and Andrew Kline, in his official capacity as the Colorado Deputy Secretary of State. Respondents
No. 24SC281
Supreme Court of Colorado, En Banc
June 29, 2026
2026 CO 56
Attorneys for Respondents: Philip J. Weiser, Attorney General Peter G. Baumann, Assistant Solicitor General Denver, Colorado
OPINION
¶1 This campaign finance dispute arising out of the 2020 election concerns whether Unite for Colorado (“Unite“) qualifies as an issue committee, a type of organization subject to registration, reporting, and disclosure requirements under Colorado‘s campaign finance laws.1
¶2 As relevant here,
¶3 First, we interpret the phrase “a major purpose” to require a fact-specific analysis of an organization‘s creation, spending, and ballot campaign-related activities, as guided by a nonexhaustive list of factors established in case law and statute at the time of this dispute. In conducting this fact-specific analysis, we interpret the phrase “any ballot issue or ballot question” to allow consideration of an organization‘s aggregate activity and spending across multiple ballot issues.
¶4 Next, we apply the fact-specific analysis to Unite to determine whether it meets
¶5 For these reasons, we reverse the judgment of the court of appeals.
¶6 Because this dispute concerns Unite‘s activities in 2020, we first summarize the relevant campaign finance laws applicable at that time.
¶7 Colorado‘s campaign finance laws can be traced back to the Campaign Reform Act of 1974, which focused on the regulation of political committees that support or oppose the nomination or election of candidates for public office. Ch. 57, sec. 1, §§ 49-27-101 to -121, 1974 Colo. Sess. Laws 261, 261-70. In 1996, voters updated and reenacted the law via a ballot measure (Amendment 15) as the Fair Campaign Practices Act (“FCPA“). Legis. Council of the Colo. Gen. Assemb., An Analysis of 1996 Ballot Proposals, at 27-32, 56-67 (1996), https://historicalelectiondata.coloradosos.gov/document/191?page=26 [https://perma.cc/P7K4-4YM9]; Colo. Sec‘y of State, State of Colorado: Abstract of Votes Cast 1995-1996, at 159, https://historicalelectiondata.coloradosos.gov/document/232?page=168 [https://perma.cc/8SGT-F9A8] (showing the abstract of votes cast for Amendment 15 in the November 5, 1996 general election). The FCPA included the regulation of issue committees that support or oppose ballot issues,
any person, other than a natural person, or any group of two or more persons, including natural persons:
(I) That has a major purpose of supporting or opposing any ballot issue or ballot question; or
(II) That has accepted or made contributions or expenditures in excess of two hundred dollars to support or oppose any ballot issue or ballot question.
Only the first prong of this definition is at issue in the majority of cases, including this one, because the Secretary of State has interpreted this provision to require an organization to meet both the major purpose element and spend in excess of two hundred dollars to qualify as an issue committee. Dep‘t of State, 8 Colo. Code Regs. 1505-6:1.9 (2022).3 Because no party disputes the Secretary of State‘s interpretation, we proceed under this interpretation.
¶9
¶10 In 2008, a division of the court of appeals first analyzed
¶11 Two years later, a different division of the court of appeals expounded on the definition of the phrase “a major purpose” in Cerbo v. Protect Colorado Jobs, Inc., 240 P.3d 495, 501 (Colo.App. 2010). There, the division examined the plain language definition of the term “major” at the time Amendment 27 passed in 2002. Id. It concluded that an organization has “a major purpose” of ballot issue advocacy if it expends “a considerable or principal portion of the organization‘s total activities” on ballot issue advocacy. Id. (quoting N.C. Right to Life, Inc. v. Leake, 525 F.3d 274, 328-29 (4th Cir. 2008) (Michael, J., dissenting)). The division also applied the phrase to Protect Colorado Jobs, Inc., and relied on several factors to assess whether the organization‘s ballot issue advocacy amounted to a considerable or principal portion of its activities. Id. at 501-04.
¶12 That same year, the General Assembly passed a new statutory definition of “a major purpose” that essentially codified the factors identified in Independence Institute. Ch. 270, sec. 4, § 1-45-103(12), 2010 Colo. Sess. Laws 1239, 1241. This new legislation stated that an organization‘s “major purpose” could be reflected by: (1) “[a]n organization‘s specifically identified objectives in its organizational documents“; or (2) “an organization‘s demonstrated pattern of conduct based upon its . . . [a]nnual expenditures in support of or opposition to a ballot issue or
¶13 Finally, in Colorado Ethics Watch v. Gessler, 2013 COA 172M, ¶¶ 32-35, 363 P.3d 727, 731-32, a division of the court of appeals rejected a rule promulgated by the Secretary of State. The rule sought to clarify that an organization has a major purpose of ballot issue advocacy if more than 30% of its annual expenditures are directed to such activity. Id. at ¶ 31, 363 P.3d at 731. The division concluded that the 30% threshold was arbitrary and capricious because it was unsupported by competent evidence and was untethered to the language in
¶14 Unite began operations in January 2020 and described itself on its website as “an issue advocacy organization” with the mission of “support[ing] policies that increase economic opportunity and greater government transparency” and “oppos[ing] policies that would be harmful to Colorado‘s economic wellbeing, and efforts to unnecessarily grow the size and reach of government.” Katie Kennedy, Unite‘s registered agent and only board member, and Dustin Zvonek, a contractor, directed all of Unite‘s activities.
¶15 In 2020, Unite spent a total of $17,174,246.70. Of that amount, $4,026,017.26, approximately 23.4%, was directed to ballot issue advocacy:
• Unite spent $1,500,808.85 opposing Proposition 113, a ballot initiative to join the National Popular Vote Interstate Compact, including spending on advertising, text messages, and direct contributions to Protect Colorado‘s Vote, an issue committee opposing Proposition 113.
• Unite spent $964,998.25 supporting Proposition 116, a ballot initiative to reduce the state income tax rate. Spending on Proposition 116 included in-kind contributions for signature gathering to support Energize our Economy, an issue committee supporting Proposition 116.
• Unite spent $1,560,210.16 supporting Proposition 117, a ballot initiative to require voter approval of certain new state-owned businesses. This spending also included advertising to support the initiative and in-kind contributions for signature gathering to Voter Approval of Fees, an issue committee supporting Proposition 117.
¶16 In August 2020, members of the public filed a campaign finance complaint against Unite with the Elections Division of the Department of State (“the Elections
¶17 After investigating the complaint, the Elections Division ultimately moved to dismiss the complaint, reasoning that Unite did not meet
¶18 However, then-Deputy Secretary of State, Ian Rayder, disagreed with this interpretation, denied the motion, and remanded the case back to the Elections Division with instructions to commence administrative proceedings against Unite for failing to register as an issue committee and make the required disclosures. The Elections Division did so, and after proceedings before the Administrative Law Judge (“ALJ“), the ALJ found that Unite had a major purpose of ballot issue advocacy because of its activities in connection with Propositions 113, 116, and 117. On review, the new Deputy Secretary of State, Christopher P. Beall, adopted the ALJ‘s findings and conclusions in part.5 The Final Agency Order adopted by
¶19 Pursuant to
¶20 A division of the court of appeals unanimously reversed the district court. Colo. Dep‘t of State v. Unite for Colo., 2024 COA 31, ¶ 1, 551 P.3d 687, 693. The division conducted its own major purpose analysis. Starting with the constitutional language in
¶21 Unite petitioned this court for a writ of certiorari. We granted review to consider the interpretation of the “major purpose” standard.6
III. Standard of Review
¶22 Issues of constitutional interpretation are questions of law subject to de novo review. Gessler v. Colo. Common Cause, 2014 CO 44, ¶ 7, 327 P.3d 232, 235. We accord administrative proceedings a “presumption of validity” and resolve “all reasonable doubts as to the correctness of administrative rulings . . . in favor of the agency.” Van Sickle v. Boyes, 797 P.2d 1267, 1272 (Colo. 1990). That said, such deference is unwarranted where “the agency‘s interpretation is contrary to constitutional and statutory law.” Gessler, ¶ 7, 327 P.3d at 235.
¶23 We begin with our guiding principles of constitutional interpretation. We then analyze the phrase “a major purpose of supporting or opposing any ballot issue or ballot question.”
A. Principles of Constitutional Interpretation
¶24 Our goal when interpreting amendments to the Colorado Constitution is twofold: effectuate the intent of the framers of our constitution and the people of the State of Colorado and prevent evasion of the constitution‘s legitimate operation. Markwell v. Cooke, 2021 CO 17, ¶ 33, 482 P.3d 422, 429. To do so, we start with the plain language of a constitutional provision, giving its terms their ordinary and popular meanings. People v. Smith, 2023 CO 40, ¶ 20, 531 P.3d 1051, 1055. That said, we may look beyond the plain and ordinary definitions of phrases
¶25 We favor constructions that harmonize different constitutional provisions over those that create conflict, and where possible, we adopt a construction consistent with those given by coordinate branches of government. In re Interrogatory on House Joint Resol. 20-1006, 2020 CO 23, ¶¶ 32-33, 500 P.3d 1053, 1062-63. We also presume that voters know the existing law when they vote to amend the constitution. Dwyer v. State, 2015 CO 58, ¶ 19, 357 P.3d 185, 191.
B. The Phrase “a Major Purpose” Demonstrates the Voters’ Intent to Adopt a Fact-Specific Analysis
¶26 Here, we begin with the plain language of the phrase “a major purpose.” We conclude that the plain language sets an overarching standard for whether an organization qualifies as an issue committee but sheds little light on how to
¶27 All these sources of the voters’ intent clarify that the major purpose test is a holistic, case-by-case assessment of an organization‘s creation, spending, and ballot campaign-related activities to determine whether it spent a considerable or principal amount of its time and resources engaging in ballot issue advocacy.
¶28 We conclude by highlighting some guiding factors from the legislature and case law that courts should consider when conducting this analysis.
1. The Plain and Ordinary Meaning of “a Major Purpose”
¶29 Common definitions of “major” and “purpose” at the time voters passed Amendment 27 offer some insight. In 2002, the Webster‘s Third New International Dictionary defined “major” as “notable or conspicuous in effect or scope: considerable, principal.” Cerbo, 240 P.3d at 501 (quoting Major, Webster‘s Third New International Dictionary (2002)). “Considerable” was defined further as “rather large in extent or degree.” Id. (quoting Considerable, Webster‘s Third New
¶30 Because the phrase “major purpose” has its origins in United States Supreme Court case law, we turn next to that history.
2. The Origins of the Major Purpose Test and Its Understanding in 2002
¶31 The Supreme Court first invoked what has come to be called the major purpose test in Buckley v. Valeo, 424 U.S. 1 (1976). Buckley concerned various challenges to the constitutionality of the Federal Election Campaign Act of 1971 (“FECA“), one of which claimed that FECA‘s definition of “political committee” was unconstitutionally vague. Id. at 7-8, 76-80. FECA defined “political committee” as a group of people that spent over one thousand dollars in a calendar year for the purpose of influencing the nomination or election of a candidate. Id. at 62-63. The Court held that this definition of “political committee” was not
¶32 The Supreme Court applied the major purpose requirement ten years later in Federal Election Commission v. Massachusetts Citizens for Life, Inc., 479 U.S. 238 (1986) (”MCFL“). MCFL concerned a constitutional challenge to a different provision of FECA that prohibited corporations from using treasury funds to make expenditures “in connection with” a federal election and required that any such expenditures be financed by voluntary contributions to a separate segregated fund. Id. at 241. FECA then regulated these separate segregated funds as political committees. Id. at 253. For a nonprofit corporation like MCFL that engaged in issue advocacy, this meant that its independent expenditure activity could be regulated as though MCFL‘s major purpose was to further the election of candidates.
¶34 From all this information, the Court concluded that MCFL was not a political committee (and therefore could not be subjected to the full panoply of regulations that accompany political committee status) because it did not have the major purpose of nominating or supporting a candidate. Id. at 241-42, 252 n.6, 262. The Court cautioned, however, that “should MCFL‘s independent spending become so extensive that the organization‘s major purpose may be regarded as campaign activity,” then it would be “classified as a political committee” and subject to FECA‘s requirements. Id. at 262 (emphasis added).
¶35 In sum, the Court examined the specific facts of MCFL‘s creation, spending, and campaign-related activities to reach its conclusion that campaign activity was not MCFL‘s major purpose. Id. at 241-44, 252 n.6, 262.7
¶37 It was against this legal backdrop that the voters in 2002 adopted Amendment 27‘s new definition of issue committee:
“Issue committee” means any person, other than a natural person, or any group of two or more persons, including natural persons:
(I) That has a major purpose of supporting or opposing any ballot issue or ballot question; [and]
(II) That has accepted or made contributions or expenditures in excess of two hundred dollars to support or oppose any ballot issue or ballot question.
¶38 This definition expressly incorporated the same major purpose language from Buckley and MCFL that we had declined to read into the earlier FCPA definition in Common Sense Alliance. And because we assume that voters knew the law at the time, we interpret the definition in section 2(10)(a) as adopting the major purpose test as articulated in Buckley and MCFL—i.e., as a fact-specific analysis of an organization‘s spending, creation, and ballot campaign-related activities. Additional evidence of the voters’ intent supports this interpretation.
¶39 The declaration that appears at the beginning of Amendment 27 serves as a guide to the voters’ intent. See Weld Cnty. Sch. Dist. RE-12 v. Bymer, 955 P.2d 550, 555 (Colo. 1998). Specifically, the voters of Colorado declared that
the interests of the public are best served by . . . full and timely disclosure of campaign contributions, independent expenditures, and funding of electioneering communications, and strong enforcement of campaign finance requirements.
¶40 The Blue Book voter guide offers additional insight into the voters’ intent. In re Submission of Interrogatories on House Bill 99-1325, 979 P.2d at 554. Specifically, the 2002 Blue Book clarifies that the disclosure provisions focused on the importance of providing the electorate with sufficient information about who is spending money to influence elections:
Requiring greater disclosure of who pays for political advertising provides more information about who is spending money to influence elections.
Legis. Council of the Colo. Gen. Assemb., 2002 Ballot Information Booklet: Analysis of Statewide Ballot Issues and Recommendations on Retention of Judges, at 6 (2002), https://hermes.cde.state.co.us/islandora/object/co%3A27117 [https://perma.cc/7W4L-BFY7].
¶41 This voter “informational interest,” like the major purpose test itself, traces its origins back to Buckley, where the Court identified it as the first of three “substantial governmental interests” that can support campaign disclosure requirements. 424 U.S. at 67-68, 81.
¶43 The information provided through disclosure requirements can be particularly valuable for voters assessing ballot propositions because they often
¶44 Given this dynamic, the disclosure of information regarding who is spending money to influence the decisions of Colorado‘s electorate is directly analogous to legislators understanding who is funding the lobbyists trying to influence their vote. See Citizens United, 558 U.S. at 369 (noting that the Court has upheld disclosure requirements for lobbyists because “Congress ‘has merely provided for a modicum of information from those who for hire attempt to influence legislation‘” (quoting United States v. Harriss, 347 U.S. 612, 625 (1954)));
4. The Major Purpose Test Requires Analyzing an Organization‘s Creation, Spending, and Ballot Campaign-Related Activities
¶45 Colorado voters adopted a definition of “issue committee” against a backdrop of case law that applied a fact-specific analysis. They prefaced it with a declaration insisting on full and timely disclosures and strong enforcement of campaign finance laws. And the Blue Book indicates that voters wanted to ensure access to full and accurate information about who is trying to influence their vote. For these reasons, we conclude that analyzing whether an organization has a “major purpose” of ballot issue advocacy requires a holistic, case-by-case assessment of an organization‘s creation, spending, and ballot campaign-related
¶46 We adopt a case-by-case analysis also to avoid interpretations that allow for easy evasion of the constitution‘s requirements. We have long considered it an obligation to “construe the constitution in such a manner as will prevent . . . evasion of its legitimate operation.” Colo. Common Cause v. Bledsoe, 810 P.2d 201, 207 (Colo. 1991) (citing Inst. for the Edu. of the Mute & Blind v. Henderson, 31 P. 714, 716 (Colo. 1892)). And campaign finance regulation is an area rife with sophisticated evasion. See Chisun Lee, et al., Secret Spending in the States, Brennan Ctr. for Just., at 6-9, 14-18 (2016), https://www.brennancenter.org/media/210/download/Report_Secret_Spending_in_the_States.pdf?inline=1 [https://perma.cc/DC3H-MYC8] (explaining the precipitous rise of undisclosed campaign finance spending on ballot measure elections, even in states—such as Colorado—with laws intended to require disclosure); see also McConnell v. Fed. Election Comm‘n, 540 U.S. 93, 176 (2003) (“Experience under the current law demonstrates that Congress’ concerns about circumvention are not merely hypothetical.“).
¶47 Accordingly, we agree with and adopt the factors identified by the division below as guidelines in determining whether an organization has a major purpose
(1) the organization‘s specifically identified objectives, as expressed in its organizational documents or in its public statements (such as on its website or in correspondence with potential donors);
(2) its activities and annual expenditures relative to its ballot-measure-related activities and expenditures;
(3) the scope of issues addressed in its print and electronic publications relative to its ballot-measure-related communications;
(4) the length of time of the organization‘s existence relative to its ballot measure advocacy;
(5) the organization‘s structure;
(6) the interrelatedness of the organization and the ballot measure‘s proponents or opponents; and
(7) the various issues with which the organization has been involved.
¶48 Some of these factors can be traced directly to the 2010 legislation. Id. (citing
¶49 Importantly, all of these factors can also be traced back to the circumstances the Supreme Court considered in MCFL. Most are drawn from Independence Institute, 209 P.3d at 1139, and Cerbo, 240 P.3d at 501-04. Both of those cases, in
¶50 Although the Court in MCFL did not list these factors explicitly, each factor captures circumstances the Court deemed relevant in that case. The Court discussed (1) the organization‘s stated purpose, MCFL, 479 U.S. at 241-42; (2) the purposes of MCFL‘s activities and its annual expenditures, id. at 242-43; (3) the scope of issues MCFL addressed in its various publications, id. at 242-44; (4) the timing of MCFL‘s election-related advocacy relative to its creation as an organization, id. at 241-44; (5) MCFL‘s organizational structure, id. at 241-42, 252-54, 259, 263-64; (6) MCFL‘s inability to serve as a “conduit[]” for the direct spending of other organizations—i.e., its (lack of) interrelatedness with other organizations, id. at 264; and (7) the various issues in which MCFL had been involved, id. at 241-44.
¶51 In short, the major purpose test is a flexible, fact-specific analysis of an organization‘s creation, spending, and ballot campaign-related activities. Because these factors carry the authority of both our legislature and Supreme Court case law, we adopt them as a nonexhaustive list of guidelines for courts to rely on when assessing whether an organization has a major purpose of ballot issue advocacy.
¶52 The parties also dispute the scope of the phrase “any ballot issue or ballot question” in
¶53 As relevant here, Unite supported or opposed three ballot issues during the 2020 election cycle: Propositions 113, 116, and 117. Unite contends that, to qualify as an issue committee, the court must determine whether it had a major purpose of supporting or opposing each specific proposition. The Secretary of State argues the opposite—that a court may assess whether Unite had a major purpose of ballot issue advocacy by examining the organization‘s activities in the aggregate.
¶54 “Any” has an expansive meaning that includes “one or more.” Any, Merriam-Webster Dictionary, https://www.merriam-webster.com/dictionary/any [https://perma.cc/37HA-PXMT]. Colorado courts have consistently interpreted “any” to mean “all.” See, e.g., Winslow v. Morgan Cnty. Comm‘rs, 697 P.2d 1141, 1141 (Colo.App. 1985) (relying on Filmore v. Wells, 15 P. 343, 345 (Colo. 1887)) (interpreting the word “any” to mean “all” when interpreting zoning requirements in the Colorado code); see also BP Am. Prod. Co. v. Colo. Dep‘t of Revenue, 2016 CO 23, ¶ 18, 369 P.3d 281, 286 (“When used as an adjective in a statute, the word ‘any’ means ‘all.‘” (quoting Stamp v. Vail Corp., 172 P.3d 437, 447
¶55 This plain language interpretation of
¶56 Finally, we note that Unite‘s interpretation that an organization‘s activities must be evaluated on a proposition-by-proposition basis would lead to absurd results. Under Unite‘s view, if an organization devotes literally 100% of its resources and activity to ballot issue advocacy but spreads those resources equally across ten separate ballot issues, that organization does not have “a major purpose of supporting or opposing any ballot issue or ballot question” because it has spent only 10% of its resources on each individual proposition. Such a result cannot be squared with the voters’ intent in passing Amendment 27.
D. Applying Article XXVIII, Section 2(10)(a) to Unite
¶57 After weighing all of the facts available in the record before us, we conclude that, while it is a close call, Unite did not have a major purpose of ballot issue advocacy during the 2020 election cycle. Of the seven factors listed above, we find four relevant to our analysis here.
¶58 First, we assess Unite‘s organizational objectives. And although Unite‘s articles of incorporation do not include a purpose statement, Unite described itself on its website as an “issue advocacy organization” with the goals of “support[ing] policies that increase economic opportunity and greater government transparency” and “oppos[ing] policies that would be harmful to Colorado‘s
¶59 Second, we consider the length of time from Unite‘s creation to its ballot issue advocacy. The record indicates that Unite began actively supporting Proposition 116 as early as April 2020, only three months after its creation in January 2020. Given this relatively short period of time between creation and supporting a ballot issue, this factor weighs in favor of a major purpose finding.
¶60 Third, we compare Unite‘s overall activities and expenditures to its ballot-initiative-related activities and expenditures. Unite spent approximately $1.5 million opposing Proposition 113 (8.7% of its total spending); approximately $965 thousand supporting Proposition 116 (5.6% of its total spending); and approximately $1.5 million supporting Proposition 117 (9.1% of its total spending). In sum, Unite spent just over $4 million across three statewide initiatives, and such a high dollar amount demonstrates a significant commitment to ballot issue advocacy. But assessing an organization‘s major purpose requires comparing its ballot campaign-related spending with its overall spending. This is essential to determine whether the ballot campaign-related spending constituted a
¶61 While we largely align with the division‘s analysis elsewhere, we disagree with the division‘s holding that directing less than a quarter of all expenditures to ballot issue advocacy supports a conclusion that an organization has a major purpose of ballot issue advocacy. Unite, ¶ 51, 551 P.3d at 701. Spending less than a quarter of all expenditures on ballot issue advocacy does not reflect a major purpose because it does not reflect a considerable or principal amount of an organization‘s overall spending. For this reason, we hold that Unite‘s ballot-initiative-related spending, relative to its total annual expenditures, weighs strongly against a major purpose finding.
¶62 Finally, we examine the interrelatedness between Unite and the propositions’ other opponents or supporters. The record indicates that Zvonek, Unite‘s contractor, met with Independence Institute, a policy think tank, in April 2020, where he discussed Unite gathering signatures to qualify Proposition 116 for the ballot. Soon after this meeting, Independence Institute created an issue committee to support Proposition 116.
¶63 Unite also made approximately $1.5 million worth of in-kind contributions to issue committees in the form of services, specifically, work to print petitions and
¶64 We emphasize this evidence of interrelatedness because—given the fact-specific nature of the major purpose analysis—slightly different facts with a similar amount of spending could support a major purpose finding. Nevertheless, Unite‘s low percentage of overall spending on ballot issue advocacy weighs strongly enough against a major purpose finding that it counterbalances the evidence of interrelatedness.
¶65 We do not apply to Unite the remaining factors (three, five, and seven) because there is insufficient evidence in the record on the facts necessary to assess those factors, namely the scope of Unite‘s activities outside of its ballot issue advocacy and whether its organizational structure indicates a major purpose of ballot issue advocacy. Again, the seven factors are a nonexhaustive list of guidelines, and they all may or may not be appropriate in any given case.
¶66 Overall, the totality of the circumstances here leads us to conclude that Unite did not have a major purpose of ballot issue advocacy during the 2020 election cycle.
¶67 The voters adopted a major purpose test with broad language and a legal history of fact-specific analysis. They did so to protect their informational interest in knowing who is trying to influence their vote and accompanied the test with a declaration insisting on full and timely disclosures achieved through strong enforcement. For these reasons, we interpret
¶68 For the foregoing reasons, we reverse the judgment of the court of appeals.
Notes
Whether the court of appeals erred in interpreting the Colorado Constitution‘s “major purpose” standard,
Colo. Const. art. XXVIII, § 2(10)(a)(I) , which qualifies an organization as an “issue committee” subject to registration, reporting, and disclosures, by adopting a multifactor test that permits a major purpose finding when an organization spends 10% or less of its total outlays supporting or opposing a particular ballot measure.
Finally, in 2022, the legislature again amended the definition of “a major purpose” in
Unite further contends that if the voters had intended to allow for aggregation of an organization‘s conduct across multiple ballot issues, they would have used “one or more” for the definition of “issue committee” as they did in the definition of “political committee.” See