Judges in Nevada and Montana threw out a handful of libertarian ballot measures in September. Montana State Judge Dirk Sandefur ruled that petition circulators engaged in a "pattern of fraud," deceiving people into signing the petitions for a trio of ballot measures in that state. The measures sought to limit land-use regulations and taxes, and make it easier to recall judges. The Nevada Supreme Court also threw out a tax-limit measure, saying petitions for it were "misleading." And Nevada cut another measure in half: It had sought to limit governments’ eminent domain powers along with land-use regulations, but state law says a ballot measure must address only one issue at a time, so the court tossed out the attack on regulations, leaving only eminent domain. Similar measures to limit eminent domain remain on the November ballots in five other Western states.