Americans for Prosperity v. Bonta

California's blanket disclosure requirement failed the narrowly-tailored test because the state could advance its fraud investigation interest through less restrictive means such as targeted disclosure upon specific investigation or complaint without requiring all charities to submit major donor lists upfront as a condition of solicitation. The Court found that the blanket requirement imposed an unnecessary burden on donors' freedom of association, chilling contributions even for donors of organizations never suspected of fraud. Although California had a legitimate interest in investigating charitable wrongdoing, the requirement's breadth and lack of meaningful limitation made it substantially broader than necessary to achieve that interest. The decision thus established that compelled disclosure regimes must be calibrated to actual investigative needs rather than applied uniformly across all solicitors.