233 when it is applied to a content-based restriction on speech. The Secretary invokes the Supreme Court’s plurality decision in. Burson v. Freeman to support his claim that contentbased speech restrictions can be justified without evidence that compelling state interests are under actual threat. There, the statute under review established a buffer zone around polling places to protect voters from solicitation and the distribution of campaign materials. Burson, 504 U.S. at 193-94, 112 S.Ct. 1846 (plurality opinion). In sustaining the statute against a First Amendment challenge, the plurality relied heavily on historical evidence demonstrating that predecessor statutes to the one under review had been adopted long ago to respond to a situation in which “[ajpproaching the polling place ... was akin to entering an open auction place.” Id. at 202, 112 S.Ct. 1846. The Court concluded that it was appropriate for the state to act without evidence of a current problem in part because the “long, uninterrupted and prevalent” use of similar statutes throughout the United States made it difficult for the state to determine what would happen if the challenged law were invalidated. Id. at 208, 112 S.Ct. 1846. Burson, however, is a very different case from the one I decide today. In contrast to the statute at issue in Burson, the 2014 amendment to RSA 659:35, I is quite new and cannot be tied to historical evidence of recent vote fraud. Although it is true that vote buying was a problem in this country before the adoption of the Australian ballot, the historical record establishes that vote buying has not been a significant factor in elections in more than 100 years. Further, because the law at issue here is new and the technology it targets has been in use for many years, it is reasonable to expect that if the problem the state fears were real, it would be able to point to some evidence that the problem currently exists. Under these circumstances, both history and common sense undermine rather than support the state’s contention that vote buying and voter coercion will occur if the state is not permitted to bar voters from displaying images of their completed ballots. Because the Secretary has failed to demonstrate that the law serves a compelling state interest, it fails to satisfy strict scrutiny. 2. Narrow Tailoring Even if the Secretary had proved that the new law serves a compelling interest, it would still fail the strict scrutiny test because it is not narrowly tailored to address the alleged state interests. When the government attempts to restrict speech in order to further a state interest, it ordinarily must demonstrate that the restriction “ ‘is narrowly tailored to achieve that interest.’” Reed, 135 S.Ct. at 2231 (quoting Am. Free Enter., 131 S.Ct. at 2817). Even content-neutral restrictions require narrow tailoring because “silencing speech is sometimes the path of least resistance ... [and] by demanding a close fit between ends and means, the tailoring requirement prevents the government from too readily ‘sacrific[ing] speech for efficiency.’” McCullen v. Coakley, — U.S. -, 134 S.Ct. 2518, 2534, 189 L.Ed.2d 502 (2014) (quoting Riley v. Nat’l Fed’n of the Blind of N.C., Inc., 487 U.S. 781, 795, 108 S.Ct. 2667, 101 L.Ed.2d 669 (1988)). This tailoring requirement is even more demanding when the state elects to restrict speech based on its content. In such cases, the burden is on the state to demonstrate that the restriction it has adopted is the “least restrictive means” available to achieve the stated objective. Ashcroft v. ACLU, 542 U.S. 656, 666, 124 S.Ct. 2783, 159 L.Ed.2d 690 (2004); McCullen v. Coakley, — U.S.

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