The commercialisation of this field is largely the consequence of the significant number of citizens’ initiated referenda that are proposed each year in California. Colorado attempted to prohibit the payment of people to collect signatures, due to fears that it would corrupt the system and allow people to ‘buy’ their way onto the ballot if they were wealthy enough. The legislation was challenged on the ground that it breached the first amendment. The US Supreme Court struck down the Colorado legislation in Meyer v Grant, holding that such laws limit the number of voices who will convey the message seeking recall and make it harder to get the matter placed
on the ballot.