The U.S. Supreme Court case Victoria Buckley, Secretary of State of Colorado v. American Constitutional Law Foundation, Inc., et al., 1998 dealt with the issue of petition circulators for ballot initiatives in the state of Colorado. The court ruled that several requirements imposed by Colorado on paid petition circulators were unconstitutional as they violated First Amendment rights to free speech and association. These included a requirement that all circulators be registered voters, wear identification badges while collecting signatures, and disclose their names and addresses publicly when submitting petitions to the secretary of state's office for verification purposes. However, it upheld one provision requiring initiative proponents to file reports disclosing who was paid how much for circulating petitions.

In the dissenting opinion for Buckley v. American Constitutional Law Foundation, Justice Rehnquist disagreed with the majority's decision to strike down Colorado's requirement that petition circulators be registered voters and wear identification badges. He argued that these requirements were not burdensome restrictions on free speech but rather reasonable regulations intended to maintain integrity in the initiative process. According to him, requiring petition circulators to be registered voters ensured they had a stake in the outcome of initiatives and helped prevent fraud by making it easier for state officials to track them down if necessary. Similarly, he believed that ID badges provided transparency by allowing potential signatories to know who was soliciting their signatures. In his view, these measures did not significantly impede political expression but instead promoted an informed electorate and protected against corruption.