A defendant in a defamation lawsuit attempted to use this case as a precedent that "sources have the right of anonymous speech under the First Amendment", but in 2011, the New Jersey Supreme Court rejected the argument, distinguishing that case from McIntyre [REF].
During the Albany, New York 2011 school budget campaign, anonymous flyers were mailed and telephones called that (unsuccessfully) aimed to defeat the Albany City School District budget [REF].