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{{law}}{{TOCnestright}}'''LIMIT v. Maleng''' is the name of a lawsuit filed in 1993 in the state of [[Washington]], challenging that state's then-newly-enacted ban on paying campaign workers who collect signatures for [[pay-per-signature|each signature they collect]].<ref>[http://www.ballot-access.org/1995/0112.html ''Ballot Access News account of overturning of HB 1645'']</ref>

The outcome of the case was that on October 17, 1994, federal judge Barbara Rothstein struck down the law.  Her ruling was not appealed by the state.

The overturned bill was [[Washington House Bill 1645 (1993)]].<ref>[http://dlr.leg.wa.gov/billsummary/default.aspx?year=1993&bill=1645 ''Bill summary of HB 1645 (1993)'']</ref>

==Background==

In 1988, in the case of [[Meyer v. Grant]], the U.S. Supreme Court had ruled that it violates the First Amendment for a state to outlaw the practice of paying anyone to circulate a petition. The law at issue in that case was from [[Colorado]].

Washington had long had a law similar to the Colorado law ruled unconstitutional in [[Meyer v. Grant]].  They believed that the new law they passed in 1993, HB 1645, would salvage as much of the old law as possible.

However, Rothstein noted there was no evidence to support the state's contention that the ban is necessary to eliminate fraud. She noted evidence presented by the plaintiff, that petitions circulated by paid workers have higher validity rates, than petitions circulated by volunteers. 

==See also==

* [[Residency requirements for petition circulators]]
* [[History of restrictions on paid circulators]]
* [[Changes in 2007 to laws governing the initiative process]]
* [[Changes in 2008 to laws governing the initiative process]]
* [[Meyer v. Grant]]
* [[Prete v. Bradbury]]

==External links==

* [http://apps.leg.wa.gov/documents/billdocs/1993-94/Pdf/Bills/House%20Bills/1645.pdf Text of HB 1645], the bill that was ruled unconstitutional in LIMIT v. Maleng

==References==
<references/>

[[Category:Initiative rights, Washington]]
[[Category:Ballot access lawsuits, Washington]]
[[Category:Laws governing the initiative process]]
[[Category:Pay-per-signature]]