Notes for reply brief.
summary of argument
summary of reply
A IC 3-9-3-2.5 might be unconstitutional.
B construe to preserve constitutionality.
C supports narrow definition.
conclusion

Majors v Abell 317 F.3d 719 (7th Cir. 2003)
Anonymous v. Delaware 2000 WL
Missouri ex rel Coker-Garcia v. Blunt

Nature of the case:
"Appellants asserted, under 42 USC 1983, that this requirement burdens their ability to engage in politicaal speech and association, in violation of the federal and state constitutions." Exactly.
We agree with defendant-appellees' statement of the case and statement of facts.

Summary of argument:
Uses the term "constitutional" to refer solely to federal constituion. insensitive to the issues of dual federalism which pervade this case.

"if that is necessary to preserve its validity."
Here, it is not sufficient, so it is not necessary.

"However, if this Court concludes that a broad interpretation of "perspns" in the challenged statute results in a finding that the statute is unconstitutional, then it is required under the canons of statutory construction to seek a narrow interpretation that will preserve the validity of the statute."

Let's follow this train of thought. Is the broad interpretation unconstitutional under the Indiana Bill of Rights? If so, how narrowly can the statute by tailored? What would cure it?
The narrower version of the statute, would be to limit the application to the list in IC 3-9-3-1, could also incorporate the holding of McIntyre, just as in BAPAC this court presumed that the legislature intended to incorporate Buckley v. Valeo.