In Meyer v. Grant, 486 U.S. 414 (1988), the Supreme Court reviewed a Colorado statute that prohibited the use of paid personnel to assist in the circulation of an initiative petition. See id. at 416. The Court struck this prohibition as violative of both the First and the Fourteenth Amendments. See id. at 428. The court noted that the circulation of an initiative petition of necessity involves both the expression of a desire for political change and a discussion of the merits of the proposed change. Although a petition circulator may not have to persuade potential signatories that a particular proposal should prevail to capture their signatures, he or she will at least have to persuade them that the matter is one deserving of the public scrutiny and debate that would attend its consideration by the whole electorate. This will in almost every case involve an explanation of the nature of the proposal and why its advocates support it. Thus, the circulation of a petition involves the type of interactive communication concerning political change that is appropriately described as "core political speech." (Id. at 421-22, 108 S. Ct. at 1891-92.)