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

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