29. ()rganizational Plaintiffs' public endeavors to collect and convey ballots for individual
Native American voters living on rural reservations are an integral part oftheir message
that the Native American vote should be encouraged and protected and that voting is
important as a manner of civic engagement.
30.
By collecting and conveying ballots, Organizational Plaintiffs are engaged in the
"unfettered interchange of ideas for the bringing about of political and social changes
desired by the people," which is at the heart of freedom ofexpression protections. Dorn
v. Bd. of Trustees of Billings Sch. Dist. No.2 (1983),203 Mont. 136, 145,661 P.zd
426,431.
31. Plaintiffs CSKT similarly engages in this exchange when
it hires
a temporar:y
worker
who collects and conveys ballots for its members.
32. Plaintiffs Fort Belknap similarly engages in this exchange when it supports third party
ballot collector and conveyors Snake Butte Voter Coalition.
33. Whether individuals should submit their ballots and ultimately participate in an election
is a "matter of societal concem that [Plaintiffs] have a right to discuss publicly without
risking criminal sanctions." Meyer,486U.S. a1421; see also Buckley,525 U.S. at 18687 (qtoting Meye r, 486 U.S. at 422).
34. Thus, the efforts of Organizational Plaintiffs, Plaintiff CSKT and PlaintiffFort Belknap
should be afforded the broadest judiciai protection.
D. BIPA
does not violate Organizational Plaintiffs, Plaintiff CSKT's, and
Fort Belknap's fundamental right to freedom of association.
35.
Plaintiff
Plaintiffs argue that BIPA also infringes on Organizational Plaintiffs', Plaintiff
CSKT's, and Plaintiff Fort Belknap's right to freedom of association. Article II,
Section 6 of Montana's Constitution protects freedom of association.
50