In determining the constitutionality of lobbyist registration laws, where do courts draw the line between lobbyists and politically active citizens? What is the difference between a citizen simply sharing their ideas with their elected officials and influencing them? In 2019, the United States Court of Appeals for the Eighth Circuit attempted to draw the line in Calzone v. Summers by holding that Missouri lobbyist registration laws violated the First Amendment as applied to an uncompensated lobbyist who incurred no expenditures relating to his lobbying efforts. This decision protects individuals who neither spend nor receive any money in connection with their political activities from the requirement that they register as lobbyists in the State of Missouri. After hearing the decision of the Eighth Circuit, the plaintiff, Ronald Calzone, stated in an interview: “It has been a long time coming, but I’m pleased that the Court of Appeals got this right. Unpaid citizen activists like myself keep our elected officials informed and accountable by sharing our views about public policy. A government cannot force unpaid activists to jump through regulatory hoops in order to exercise their First Amendment rights.”

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