95. Under strict scruliny, "the govemment must show that the law is narrowly tailored to serve a compelling government interest." Mont. Cannabis Indus. Ass'n, 96. As Defendants caffrot make I16. tlat showing, BIPA should be enjoined. 97. BIPA does not serve a compelling govemmental interest. 98. The only stated govemmental interest for BIPA was to stop unsolicited ballot collection and to prevent ballot interference. 99. Yet, uniform testimony by election administrators and State of Montana officials was that unsolicited ballot collection and ballot interference was not and has never been a problem in Montana. 100. The Court places great weight to this testimony because election administrators have firsthand knowledge 101. ofhow elections in Montana are administered. Thus, aside from the bill sponsor's assertion at hearing, nothing in the legislative record supports a frnding that Montana has or ever had a problem with unsolicited ballot collection or that ballot interference represents a compelling government interest in Montana. 102. The State admits there is not a single example of voter fraud in Montana caused by ballot collection. 103. However, assuming arguendo that unsolicited ballot collection is a compelling interest, BIPA is not narrowly tailored enough to meet this interest. 104. BIPA applies to a/i ballots collected, even when affirmatively solicited by voters themselves. In the words of the clerks in charge of running elections, BIPA targets voters who are doing things right, rather than creating a deterrent for the people who would do things wrong. 58

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