The Plaintiffs argued that their request for a Preliminary Injunction should be granted because the signatures need to be personally witnessed which means the registered voters need to sign the petition in close proximity to the person circulating it. This would risk illness and death for all the circulators and people signing the petition. Additionally, they argue the state's interest in avoiding ballot clutter and voter confusion cannot be served by requiring independent candidates and their supports to engage in an activity that would involve substantial risk to human life. The Plaintiff's further argue the Court applying strict scrutiny does not need to consider whether Plaintiffs were reasonably diligent but even so no reasonably diligent candidate could comply with the ballot access requirements. | Kishore v. Newsom C.D. Cal.