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LIMIT v. Maleng

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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 each signature they collect.[1]

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).[2]


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

External links

  • Text of HB 1645, the bill that was ruled unconstitutional in LIMIT v. Maleng


  1. Ballot Access News account of overturning of HB 1645
  2. Bill summary of HB 1645 (1993)