On February 17, U.S. District Court Judge Susan Dlott struck down an Ohio law that makes it illegal for a former state legislator to lobby the legislature within 12 months of leaving the legislature. The law even makes it illegal for state legislators to lobby as volunteers. The decision said the ban violates the First Amendment. Brinkman v Budish, U.S. District Court, Southern Dist., 1:09-cv-326. The 16-page decision suggests that the law would be constitutional if it only related to paid lobbying.