• Oregon Attorney General Opinion OP-8266 (1999): This is a critical reference for your memo. The Oregon AG explicitly advised that ORS 260.522—Oregon’s disclaimer statute—was unconstitutional on its face under Article I, Section 8. The opinion noted that because the law targets "speech per se" (specifically the act of anonymous publishing), it violates the state constitution regardless of whether a "compelling interest" exists.
• Deras v. Myers, 272 Or. 47 (1975): A landmark case where the Oregon Supreme Court struck down campaign expenditure limits. The court emphasized that the state constitution protects individual expression over legislative attempts to regulate campaign financing and rejected the use of a federal-style "balancing test" to override state constitutional rights.
• Vannatta v. Keisling, 324 Or. 514 (1997): The court held that the Oregon Constitution prohibits laws that restrain the "free expression of opinion," including most limits on political contributions or expenditures. It established that laws directed at the content of speech are unconstitutional per se.
• State v. Robertson, 293 Or. 402 (1982): While not specifically a disclaimer case, this is the controlling framework for all Oregon free speech claims. It categorizes laws into three levels; disclaimer laws fall into "Category 1" (laws directed at the content of speech), which are generally invalid on their face unless they fall into a historical exception like perjury or fraud.
• State v. Ciancanelli, 339 Or. 282 (2005): Reaffirmed that the framers of the Oregon Constitution intended to prohibit broadly any laws directed at restraining the expression of ideas of any kind. 

Why Oregon Supports Your Argument

1. Tennessee Attorney General Opinion 95-090

• The Original Stance: In 1995, following the McIntyre decision, the Tennessee AG explicitly concluded that T.C.A. § 2-19-120 (the state's disclaimer law) was unconstitutional because it prohibited anonymous campaign materials for both candidates and ballot measures.
• The Shift: However, in 2018 (Opinion 18-37), the AG updated this stance, claiming the 1995 opinion was "obsolete" because the legislature had since amended the law to apply only to candidate elections (avoiding the ballot measure issue in McIntyre). This confirms that the state AG once viewed the law as a direct violation but now relies on
• Maryland Attorney General Guidance
  • Individual Exception: The Maryland Attorney General previously concluded that while disclosure laws generally stand, the McIntyre decision invalidates prohibitions on anonymous campaign materials when applied to an individual acting independently.
  • Compelled Speech Context: More recently, the Maryland AG’s office has faced federal court rulings (like Washington Post v. McManus) which found that state laws requiring platforms to disclose political speakers are a form of compelled speech that must satisfy strict scrutiny. 
  • AG Opinion 95-039 (May 15, 1995): This is the definitive "on point" opinion. Issued less than a month after McIntyre, AG Don Stenberg explicitly stated that Neb. Rev. Stat. § 49-1474.01—which prohibited anonymous campaign literature—was "clearly unconstitutional". The AG noted that the Nebraska statute was "indistinguishable" from the Ohio law struck down in McIntyre.
  • AG Opinion 95-040 (May 16, 1995): Issued the following day, this opinion expanded on the state’s lack of authority to curb anonymous speech. It emphasized that while preventing fraud and libel are important state interests, they do not justify a blanket ban on anonymous speech when other anti-fraud statutes already exist.
  • but there's a newer one so careful
  • 
    
•