In Riley v. Nat'l Fed'n of the Blind of North Carolina, 487 U.S. 781, 101 L. Ed. 2d 669, 108 S. Ct. 2667 (1988), the United States Supreme Court declared unconstitutional a North Carolina charitable solicitations statute that defined a prima facie "reasonable fee" that a professional fundraiser may charge as a percentage of the funds solicited. 487 U.S. at 785-795. The Court held that the statute violated the First Amendment since it sometimes required the fundraiser to rebut a prima facie case that the solicitor's fee was unreasonable. See 487 U.S. at 793-95.