Lower Court Cases Upholding Disclaimer Requirements 

• Gaspee Project v. Mederos (1st Cir. 2021): The First Circuit upheld a Rhode Island law requiring "top five" donor disclaimers directly on independent expenditure advertisements. The court used "exacting scrutiny" to rule that the state’s interest in an informed electorate outweighed the speaker's right to anonymity, despite the plaintiff's reliance on the Talley/McIntyre tradition.
• No on E v. Chiu (9th Cir. 2024): The Ninth Circuit upheld a San Francisco ordinance requiring political ads to include a disclaimer listing the "top three" donors of its donors (secondary donors). The court explicitly distinguished this from Talley by arguing that the modern interest in "electoral integrity" justifies compelling this much text on the face of a message.
• Yamada v. Snipes (9th Cir. 2015): Upheld Hawaii’s requirement for disclaimers on "electioneering communications" and independent expenditures. The court followed the Citizens United logic, effectively ruling that the Talley anonymity right essentially vanishes once speech moves from a "private handbill" to a "mass communication" format.
• Vermont Right to Life Committee, Inc. v. Sorrell (2d Cir. 2014): The Second Circuit upheld Vermont’s disclaimer laws for electioneering communications. The committee argued that the disclaimers were a burden on their speech, but the court ruled that the "informational interest" was paramount, a reasoning often criticized as being at odds with the Talley holding.
• Majors v. Abell (7th Cir. 2003):
•  In an opinion by Judge Posner, the Seventh Circuit upheld an Indiana law requiring disclaimers on almost all political literature. Posner acknowledged the tension with McIntyre and Talley but concluded that the Supreme Court’s overall trend toward transparency in elections limited the anonymity right to the specific facts of McIntyre (a lone citizen with a handbill). 
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• seymour ct
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• gable v patton
• ky rtl v terry 
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• State v. Meta Platforms, Inc. (Wash. Ct. App. 2024): In the appellate ruling you mentioned, the court relied on the same "transparency" logic rooted in cases like Kentucky Right to Life to reject First Amendment defenses against compelled sponsor identification in digital ads.
• Seymour v. Elections Enforcement Commission (Conn. 2000): As we d
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• 29 The statute directs that “The documents and books of account” in question must include: “(a) The names and addresses of persons from whom it accepted political advertising or electioneering communications; (b) The exact nature and extent of the services rendered; and (c) The total cost and the manner of payment for the services.” RCW 42.17A.345(1). 
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