Yesterday the Ninth Circuit decided Caruso v. Yamhill County, upholding an Oregon requirement that ballot measures proposing local option taxes include a statement: “This measure may cause property taxes to increase more than three percent.” The court rejected a First Amendment challenge, distinguishing both McIntyre and Cook v. Gralike. This is a very interesting case, given that the statement must be in the initiative itself, rather than part of any report from a legislative analyst.