; Americans for Prosperity Foundation v. Bonta, 141 S. Ct. 2373 (2021). (6) Most recently, in Americans for Prosperity Foundation v. Bonta, 141 S. Ct. 2373 (2021), a California law required Americans for Prosperity Foundation and the Thomas Moore Law Center to disclose the names, contribution amounts, and addresses of their major donors. Id. at 2380. The Supreme Court held this substantial intrusion into the group’s donors was unconstitutional. Id. at 2389. While Attorney General Bonta argued these disclosures were needed so California could prevent wrongdoing by charitable organizations, there was not a single, concrete instance in which pre-investigation collection of [this information] did anything to advance the Attorney General's investigative, regulatory or enforcement efforts. Id. at 2386. Similarly, California’s need for this information before initiating an investigation was highly questionable as it was only one of three states to impose this requirement and did not seriously enforce it until 2010. Id. at 2387. (7) In short, Americans for Prosperity Foundation and NAACP both stand for the proposition that compelled disclosure of an organization’s members can violate an organization’s freedom of association. This is because effective advocacy of both public and private points of view, particularly controversial ones, is undeniably enhanced by group association and there is a vital relationship between freedom to associate and privacy in one's associations . . . See Id. at 2382 citing NAACP v. Alabama ex rel. Patterson, 357 U.S. 449, 460–462. (8) Unfortunately, the First Amendment’s freedom of association protections are under constant attack. Recently, there have been efforts to enlarge the size of the Supreme Court because of disagreement with some of its rulings and personal disagreement with some of the justices. (9) On April 9, 2021, the President issued Executive Order 14023 that created the Presidential Commission on the Supreme Court (the Commission). Under section 3(iii) of that Executive Order,