In McIntyre v. Ohio Elections Commission, the Supreme Court ruled that a state statute banning anonymous campaign literature "designed to influence voters" was:

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The Supreme Court ruled that the statute banning anonymous campaign literature was an unconstitutional subject matter regulation because it violated the First Amendment right to anonymous speech. The Court stated that the statute was overly broad and could chill political speech and association. The Court also noted that there were other ways to address potentially fraudulent or libelous speech without completely banning anonymous campaign literature.

In McIntyre V