In McIntyre v. Ohio Elections Com'n, 514 U.S. 334, 347, 131 L. Ed. 2d 426, 115 S. Ct. 1511 (1995), the Supreme Court addressed an Ohio law mandating that any published statement designed to influence voters in an election with respect to a candidate or issue must contain the name and address of the person or organization responsible for its issuance. McIntyre, 514 U.S. at 357. The Court held the statute unconstitutional because the state's interest in providing voters with additional relevant information did not justify the requirement that a writer make statements or disclosures he would have otherwise omitted. Id. The Court also held that Ohio's prohibition against anonymous political statements was not its principal weapon against fraud, but was merely a deterrent and aid to enforcement. McIntyre, 514 U.S. at 350-51. The ancillary benefits to the state did not justify the broad reach of the statute. McIntyre, 514 U.S. at 350.