234 502 189 L.Ed.2d —, 134 S.Ct. 2518, 2530, (2014) (dictum); Globe Newspaper Co. v. Pokaski, 868 F.2d 497, 505 (1st Cir.1989); but cf. Williams-Yulee v. Fla. Barr — 135 S.Ct. 1656, 1671, 191 U.S. -, (2015) (narrow tailoring does 570 L.Ed.2d not require perfect tailoring even when a content-based speech restriction is under review). Among other reasons, a law is not narrowly tailored if it is significantly overin-clusive. See Brown, 131 S.Ct. at 2741; Simon & Schuster, Inc. v. Members of N.Y. State Crime Victims Bd., 502 U.S. 105, 121, 123, 112 S.Ct. 501, 116 L.Ed.2d 476 (1991); First Nat’l Bank of Boston v. Bellotti, 435 U.S. 765, 794-95, 98 S.Ct. 1407, 65 L.Ed.2d 707 (1978). For example, in Simon & Schuster, Inc. v. Members óf New York State Crime Victims Board, the law at issue required that an accused or convicted criminal’s income from works describing his crime be deposited in an escrow account and made available to the victims of the crime and the criminal’s other creditors. 502 U.S. at 108, 112 S.Ct. 501. The Supreme Court held that the law was a “significantly overinclusive” means of ensuring that victims are compensated from the proceeds of crime, and therefore the law was not narrowly tailored. Id. at 121, 123, 112 S.pt. 501. Describing the reach of the statute, the Court stated: Should, a prominent figure write his autobiography at the end of his career, and include in an early chapter a brief recollection of having stolen .... a nearly worthless item as a youthful prank, the [government entity]..would control his entire income from the. book, for five years, and would make that income available to all. of the author’s creditors .... Id. at -123, 112 S.Ct. 501. That is, the statute applied to a wide range of literature that would not enable a criminal to profit while a victim remained uncompensated. Because the law covered far more material than necessary to accomplish its goals, the Court held that the statute was vastly overinclusive and therefore not narrowly tailored. Id. Here, like the law at issue in Simon & Schuster, the 2014 amendment to RSA 659:35,1 is vastly overinclusive and is therefore not narrowly tailored to further a compelling interest. Even if the Secretary could demonstrate that New Hampshire has an actual problem with either vote buying or voter coercion and that allowing voters to display images of their ballots would exacerbate either problem, the means that the state has chosen to address the issue will, for the most part, punish only the innocent while leaving actual participants in vote buying and voter coercion schemes unscathed. As the complaints of the voters who are now under investigation reveal, the people who are most likely to be ensnared by the new-law are those who wish to use images of their completed ballots to make a political point. The few who might be drawn into efforts to buy or coerce their votes are highly unlikely to broadcast their intentions via social media given the criminal nature of the schemes in which they have become involved. As a result, investigative efforts will naturally tend to focus on the low-hanging fruit of innocent voters who simply want the world to know how they have voted for, entirely legitimate reasons. When content-based speech restrictions target .vast amounts of protected political speech in an effort to address a tiny subset of speech that, presents a. problem, the speech restriction simply cannot stand if other less restrictive alternatives exist. Because the 2014 amendment is a content-based restriction on speech, it falls to the government to demonstrate that less speech-restrictive alternatives will not work. Playboy, 529 U.S. at 816, 120 S.Ct.

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