of review lower than strict scrutiny, which the Court defined as "exacting scrutiny."<ref>See, e.g., ; ; .</ref> Exacting scrutiny "requires a 'substantial relation' between the disclosure requirement and a 'sufficiently important' government interest." The Washington State Public Records Act (PRA) survived exacting scrutiny because the Court felt the state had a sufficiently important government interest in "preserving electoral integrity." The Court noted that the state was not only protecting against fraud, but also "simple mistake, such as duplicate signatures or signatures of individuals who are not registered to vote in the State." Even though the secretary of state is charged with reviewing the signatures, he only reviews 3 to 5% of them. "Public disclosure can help cure the inadequacies of the verification and canvassing process." Ultimately, the Court concluded that "public disclosure of referendum petitions in general is substantially related to the important interest of preserving the integrity of the electoral process." The Court did clarify that the broad ruling in this case does not preclude a narrower holding in a future case in which a plaintiff can show "'a reasonable probability that the compelled disclosure [of personal information] will subject them to threats, harassment, or reprisals from either Government officials or private parties.'” Buckley, supra, at 74, 96 S.Ct. 612; see also Citizens United, 558 U.S., at ––––, 130 S.Ct., at 915. However, in most cases referendums have to do with subjects such as "'tax policy, revenue, budget, or other state law issues'. . . Voters care about such issues, some quite deeply—but there is no reason to assume that any burdens imposed by disclosure of typical referendum petitions would be remotely like the burdens plaintiffs fear in this case." In this case, plaintiffs failed to provide any specific evidence to show that people who voted on this referendum would face such obstacles. The Court "conclude[d] that disclosure under the PRA would not violate the First Amendment with respect to referendum petitions in general and therefore affirm[ed] the judgment of the Court of Appeals." Justice Clarence Thomas, in the lone dissenting opinion, argued that the PRA severely burdens the First Amendment right to free speech and "chills participation in the referendum process." See also List of United States Supreme Court cases, volume 561 James Bopp Related CasesNAACP v. AlabamaBrown v. Socialist Workers ’74 Campaign CommitteeMcIntyre v. Ohio Elections CommissionReferences External links Who is Publius? or, Who's Afraid of Anonymous