224 1. Evidence of Vote Buying and Voter Coercion in New Hampshire The legislative history of the 2014 amendment to RSA 659:35 contains only a single reference to ■an actual alléged instance of vote buying in New Hampshire. As Representative Till described the incident: I was told by a Goffstown resident that he knew for a fact that one of the major parties paid students from St Anselm’s $50 to vote in the. 2012 election. I don’t know whether that is true or not, but I do know that if I were going to pay someone to vote a particular way, I would want proof that they actually voted that way. Legislative History at 000064. She did not provide any other details about the incident, and it is not discussed elsewhere in the legislative history. The summary judgment record does not include any evidence that either vote buying or voter coercion has occurred in New Hampshire since the late 1800s. See Doc. No. 18-1 at 2. Moreover, the state has received no complaints that images of marked ballots have been used to buy or coerce other votes. See Exhibit B to the Declaration of Gilíes Bissonnette, Esq. in Support of Plaintiffs’ Motion for Summary Judgment (“Exhibit B”) at 11, Rideout v. Gardner, No. 14-cv-489-PB (filed Mar.'27, 2015). 2. Vote Buying and Voter Coercion in the United States There is no doubt that vote buying and voter coercion were at one time significant problems in the United States. See Doe v. Reed, 561 U.S. 186, 226, 130 S.Ct. 2811, 177 L.Ed.2d 493 (2010) (Scalia, J., concurring) (citing Burson v. Freeman, 504 U.S. 191, 202, 112 S.Ct. 1846, 119 L.Ed.2d 5 (1992) (plurality opinion)); Susan C. Stokes, et al., Brokers, Voters, and Clien-telism: The Puzzle of Distributive Politics 200 (2013); Richard Hasen, Vote Buying, 88 Cal. L.Rev. 1323, 1327 (2000); Jill Lepore, Rock, Paper, Scissors: How We Used To Vote, New Yorker, Oct. 13, 2008, http://www.newyorker.com/magazine/2008/ 10/13/rock-paper-scissors. Initially, the United States followed the viva voce system of voting used in England, in which voting “was not a private affair, but an open, public decision, witnessed by all and improperly influenced by some.” Burson, 504 U.S. at 200, 112 S.Ct. 1846. Gradually, states repealed the viva voce system in favor of written ballots. Id. At first, voters were expected to provide their own pen and paper, but when that became too complex, parties provided voters with printed ballot paper with a “ready-made slate of candidates.” L.E. Fredman, The Australian Ballot: The Story of an American Reform 21 (1968). • Because early written ballots were not secret ballots, they provided an opportunity for parties to buy votes. The parties used ballot paper that “was colored or otherwise recognizable” from a distance to ensure that the voter used the ballot he was given. Id. at 22; see Burson, 504 U.S. at 200, 112 S.Ct. 1846. Ballot peddlers or district captains then paid voters as .they emerged from the polling place. Fredman, supra, at 22. For instance, in 1892, 16% of Connecticut voters were “up for sale” at prices-ranging from $2 to $20. Id. at 23. ■Similarly, in 1887, a “study of New York City politics estimated that one-fifth of voters were bribed.” Stokes, supra, at 227. By the end of the 19th century, most' of the United States had adopted a new voting method referred to as the “Australian ballot.” Fredman, supra, at 83. The Australian ballot is a method of voting using a secret ballot that was first used in Australia in the mid-19th century. Id. at 7-9. It has four characteristics: (1) ballots are