Saturday, May 23, 2026

 to do:

letter to alaska. print and mail. 

hava complaint form. print and mail and handdeleiver

outline alaska amicus.

review chiu ethics threat letter

outline a m otion for rehearting in h h case.

make a list online for jay

write up the letter to the cop, michelle, etc. 

wait dustin was here today? 

meet  w sherry and dusty

i need a list a budget and a schedule

  • Alaska Letter: Print, sign, and mail to the court and counsel.
  • HAVA Complaint: Print, mail, and hand-deliver to the election office.
  • Alaska Amicus: Draft the core outline based on the new 2026 cases.
  • Chiu Letter: Review the ethics threat and note defensive points.
  • H H Case Rehearing: Outline the core procedural and substantive errors.
  • Jay's Online List: Compile and upload the specific tasks for Jay.
  • Police/Michelle Letter: Write the formal statement to the police and Michelle.
  • Sherry/Dusty Meeting: Prepare your core talking points before they arrive.


 IN THE SUPREME COURT FOR THE STATE OF ALASKA


Alaska Policy Forum,
          Petitioner,
v.                                         Supreme Court No. S-18533
Alaska Public Offices Commission,
          Respondent.

____________________________________________________________________

NOTICE OF SUPPLEMENTAL AUTHORITY
____________________________________________________________________

TO THE CLERK OF THE COURT AND ALL PARTIES OF RECORD:

The Alaska Supreme Court issued its decision on February 13, 2026. The U.S. Supreme Court immediately shifted the constitutional ground by issuing Chiles v. Salazar on March 31, 2026, and First Choice Women's Resource Centers v. Davenport on April 29, 2026. These intervening decisions establish that topic-specific compelled disclaimers cause an immediate, content-based First Amendment injury, completely invalidating the Alaska framework. The certiorari petition deadline is July 13th, 2026. This court has an opportunity to revise its decision. Otherwise, the U.S. Supreme Court is likely to remand for consideration in light of Chiles v. Salazar.

Dated: May 23, 2026

Respectfully submitted,

_______________________________________
Amicus Curiae


CERTIFICATE OF SERVICE

I hereby certify that on this 23rd day of May, 2026, a true and correct copy of the foregoing Notice of Supplemental Authority was served via first-class U.S. Mail, postage prepaid, upon the Clerk of the Appellate Courts and the following counsel of record:

Stacey Stone, Esq.
Holmes Weddle & Barcott, P.C.
701 West 8th Avenue, Suite 700
Anchorage, AK 99501

Scott Kendall, Esq.
Condon Partch & Kendall
500 L Street, Suite 300
Anchorage, AK 99501

Office of the Attorney General
Alaska Department of Law - Civil Division
1031 West 4th Avenue, Suite 200
Anchorage, AK 99501


_______________________________________
Amicus Curiae


 alley v. California, 362 U.S. 60 (1960); People v. Bongiorni, 205 Cal. App. 2d Supp. 856 (1962); Ghafari v. Municipal Court, 87 Cal. App. 3d 255 (1978); People v. Drake, 97 Cal. App. 3d Supp. 32 (1979); Schuster v. Municipal Court, 109 Cal. App. 3d 887 (1980); Griset v. Fair Political Practices Com., 8 Cal. 4th 851 (1994); id., 69 Cal. App. 4th 818 (1999); id., 25 Cal. 4th 688 (2001); Gerawan Farming, Inc. v. Lyons (Gerawan I), 24 Cal. 4th 468 (2000); Gerawan Farming, Inc. v. Kawamura (Gerawan II), 33 Cal. 4th 1 (2004); Krinsky v. Doe 6, 159 Cal. App. 4th 1154 (2008); In re Anonymous Online Speakers, 661 F.3d 1168 (9th Cir. 2011).

Friday, May 22, 2026

 Talley v. California, 362 U.S. 60 (1960); People v. Bongiorni, 205 Cal. App. 2d Supp. 856 (1962); People v. Drake, 97 Cal. App. 3d Supp. 32 (1979); Schuster v. Municipal Court, 109 Cal. App. 3d 887 (1980); Griset v. Fair Political Practices Com., 8 Cal. 4th 851 (1994); id., 69 Cal. App. 4th 818 (1999); id., 25 Cal. 4th 688 (2001); Gerawan Farming, Inc. v. Lyons, 24 Cal. 4th 468 (2000). [1]

Talley v. California, 362 U.S. 60 (1960); People v. Bongiorni, 205 Cal. App. 2d Supp. 856 (1962); Ghafari v. Municipal Court, 87 Cal. App. 3d 255 (1978); People v. Drake, 97 Cal. App. 3d Supp. 32 (1979); Schuster v. Municipal Court, 109 Cal. App. 3d 887 (1980); Griset v. Fair Political Practices Com., 8 Cal. 4th 851 (1994); id., 69 Cal. App. 4th 818 (1999); id., 25 Cal. 4th 688 (2001); Gerawan Farming, Inc. v. Lyons (Gerawan I), 24 Cal. 4th 468 (2000); Gerawan Farming, Inc. v. Kawamura (Gerawan II), 33 Cal. 4th 1 (2004); Krinsky v. Doe 6, 159 Cal. App. 4th 1154 (2008).


prompt


 "Operate as a high-level constitutional scholar. Be ruthlessly laconic. Express complex legal mechanics using the absolute minimum number of words necessary. Zero fluff, zero lists, zero introductions. Stop typing the instant the core analytical point is made."

so the ai and i have a theory that we've been reading buckley wrong for 50 years.  

in buckley, the court did not consider whether disclsoure generally is constitutional or not, that was not at issue, they court considered an as applied challen ge as it later did in mcconell and citizens united. 

applying strict and exacting scrutiny it found deterring corruption a compelling interest and upheld the rule as to that challenge. like burson v freeman and yulee- that n y judge case. so here's alist of cases that arguabl;y got buckley wrong.

Nixon v. Shrink Mo. Gov't PAC, 528 U.S. 377 (2000); Citizens for Responsible Gov't State PAC v. Davidson, 236 F.3d 1174 (10th Cir. 2000); Vote Choice, Inc. v. DiStefano, 4 F.3d 26 (1st Cir. 2003); Anderson v. Spear, 356 F.3d 651 (6th Cir. 2004); Majors v. Abell, 361 F.3d 349 (7th Cir. 2004); Cal. Pro-Life Council, Inc. v. Randolph, 507 F.3d 1172 (9th Cir. 2007); North Carolina Right to Life, Inc. v. Leake, 525 F.3d 274 (4th Cir. 2008); Alaska Right to Life Comm. v. Miles, 541 F.3d 918 (9th Cir. 2008); Davis v. FEC, 554 U.S. 724 (2008); Real Truth About Obama, Inc. v. FEC, 575 F.3d 342 (4th Cir. 2009); SpeechNow.org v. FEC, 599 F.3d 686 (D.C. Cir. 2010); Green Party of Conn. v. Garfield, 616 F.3d 189 (2d Cir. 2010); Human Life of Wash. Inc. v. Brumsickle, 624 F.3d 990 (9th Cir. 2010); National Organization for Marriage v. McKee, 649 F.3d 34 (1st Cir. 2011) [INDEX]; Chula Vista Citizens for a Fair Co-Op v. Sandoval, 658 F.3d 1029 (9th Cir. 2011); Minnesota Citizens Concerned for Life, Inc. v. Swanson, 692 F.3d 864 (8th Cir. 2012); Ctr. for Individual Freedom v. Madigan, 697 F.3d 464 (7th Cir. 2012); The Real Truth About Obama, Inc. v. FEC, 688 F.3d 136 (4th Cir. 2012)

 Rejection of the Informational Interest: In candidate elections, knowing who funds a candidate is crucial for voters. In independent issue referenda (like a school tax levy), the Court ruled that the author's name carries no weight or informational value to the reader.

wrong quote. i'll try again. i'm rereading buckley p 64. the buckley test is not what we were told. 

In some instances, disclosure may even expose contributors to harassment or retaliation. These are not insignificant burdens on individual rights, and they must be weighed carefully against the interests which Congress has sought to promote by this legislation. In this process, we note and agree with appellants' concession81 that disclosure requirements certainly in most applications appear to be the least restrictive means of curbing the evils of campaign ignorance and corruption that Congress found to exist.82  

REPORTING AND DISCLOSURE REQUIREMENTS Unlike the limitations on contributions and expenditures imposed by 18 U.S.C. § 608 (1970 ed., Supp. IV), the disclosure requirements of the Act, 2 U.S.C. § 431 et seq. (1970 ed., Supp. IV), [Footnote 68] are not challenged by appellants as per se unconstitutional restrictions on the exercise of First Amendment freedoms of speech and association. [Footnote 69] Indeed, appellants argue that "narrowly drawn disclosure requirements are the proper solution to virtually all of the evils Congress sought to remedy." Brief for Appellants 171. 

marilyn.odendahl@indianacitizen.org


Since NAACP v. Alabama, we have required that the subordinating interests of the State must survive exacting scrutiny. [Footnote 73] We also have insisted that there be a "relevant correlation" [Footnote 74] or "substantial relation" [Footnote 75] between the governmental interest and the information required to be disclosed. See Pollard v. Roberts, 283 F. Supp. 248, 257 (ED Ark.) (three-judge court), aff'd, 393 U. S. 14 (1968)

here, the court says exacting scrutiny, footnoiting the civil rights cases. it didn not define and is not using a term of art. AND it must show a relevant correlatyion.

Since NAACP v. Alabama, we have required that the subordinating interests of the State must survive exacting scrutiny. [Footnote 73] We also have insisted that there be a "relevant correlation" [Footnote 74] or "substantial relation" [Footnote 75] between the governmental interest and the information required to be disclosed. See Pollard v. Roberts, 283 F. Supp. 248, 257 (ED Ark.) (three-judge court), aff'd, 393 U. S. 14 (1968)


73 NAACP v. Alabama, 357 U.S. at 357 U. S. 463See also Gibson v. Florida Legislative Comm., 372 U. S. 539372 U. S. 546 (1963); NAACP v. Button, 371 U.S. at 371 U. S. 438Bates v. Little Rock, 361 U.S. at 361 U. S. 524.

The strict test established by NAACP v. Alabama is necessary because compelled disclosure has the potential for substantially infringing the exercise of First Amendment rights. 

the court uses the word strict to describe the scrutiny it is using.

p 65 The disclosure requirements, as a general matter, directly serve substantial governmental interests. In determining whether these interests are sufficient to justify the requirements, we must look to the extent of the burden that they place on individual rights.

is that where they got substasntial from? deter corruption and appearasnce of corruption. compelling interest.

It is undoubtedly true that public disclosure of contributions to candidates and political parties will deter some individuals who otherwise might contribute. In some instances, disclosure may even expose contributors to harassment or retaliation. These are not insignificant burdens on individual rights, and they must be weighed carefully against the interests which Congress has sought to promote by this legislation. In this process, we note and agree with appellants' concession [Footnote 81] that disclosure requirements -- certainly in most applications -- appear to be the least restrictive means of curbing the evils of campaign ignorance and corruption that Congress found to exist. [Footnote 82] Appellants argue, however, that the balance tips against disclosure when it is required of contributors to certain parties and candidates. We turn now to this contention.

and therefore found no

tenable rationale for assuming that the public interest in minority party disclosure of contributions above a reasonable cutoff point is uniformly outweighed by potential contributors' associational rights,

We are not unmindful that the damage done by disclosure to the associational interests of the minor parties and their members and to supporters of independents could be significant. These movements are less likely to have a sound financial base, and thus are more vulnerable to fall-offs in contributions. In some instances, fears of reprisal may deter contributions to the point where the movement cannot survive. The public interest also suffers if that result comes to pass, for there is a consequent reduction in the free circulation of ideas both within [Footnote 85] and without [Footnote 86] the political arena.

On this record, the substantial public interest in disclosure identified by the legislative history of this Act outweighs the harm generally alleged.

An opinion dissenting in part from the Court of Appeals' decision concedes

oh! there's a partial dissent below, should read it to argue the point later.

buckley is a unified executive case, a separation of powers landmark. when did unified executive come back into play? (humphrey's executor narrowed)