Sitting by designation, in his concurrence in "Kruse v. City of Cincinnati," Cohn wrote: "The Supreme Court's decision in "Buckley", however, is not a broad pronouncement declaring all campaign expenditure limits unconstitutional. It may be possible to develop a factual record to establish that the interest in freeing officeholders from the pressures of fundraising so they can perform their duties, or the interest in preserving faith in our democracy, is compelling, and that campaign expenditure limits are a narrowly tailored means of serving such an interest."