McIntyre v. Ohio Elections Commn. Case brief

McIntyre v. Ohio Elections Commn. Case brief summary
514 U.S. 334 (1995)

CASE SYNOPSIS

Petitioner was granted certiorari and sought review of an order of the Ohio Supreme Court affirming the imposition of a fine under Ohio Rev. Code Ann. § 3599.09(A), which prohibited distribution of anonymous campaign literature.

CASE FACTS
Petitioner distributed anonymous leaflets regarding a proposed school tax levy in violation of Ohio Rev. Code Ann. § 3599.09(A), which prohibited distribution of anonymous campaign literature, and was assessed a fine. In reversing her fine, the Court held an author's decision to remain anonymous was protected by U.S. Constitutional Amendment I.

DISCUSSION

• Applying exacting scrutiny, the Court invalidated the statute as it was not narrowly tailored to serve an overriding state interest. 
• Respondent's interest in providing voters with additional relevant information was insufficient to support the constitutionality of the statute. 
• Though respondent had an interest in preventing fraud and libel, the statute punished fraud indirectly by indiscriminately outlawing a category of speech, based on content, with no necessary relationship to the danger sought to be prevented. 
• Respondent failed to show its interest in preventing the misuse of anonymous election-related speech justified a prohibition of all uses of that speech.

CONCLUSION

Order affirming imposition of fine under Ohio Rev. Code Ann. § 3599.09(A) was reversed because the statute violated the First Amendment as it was not narrowly tailored to serve an overriding state interest; the statute indiscriminately outlawed a category of speech with no relationship to the danger sought to be prevented.