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And lately one part of this problem has been most glaring to volunteers who comb beaches picking up trash: cigarette butts

The Government Accountability Office study, which will be the focus of a congressional hearing on Tuesday, found that Childrens Health Insurance Program Reauthorization Act (CHIPRA) drove manufacturers and price-conscious consumers to gravitate to pipe tobacco and so-called large cigars because it taxed them at lower rates than cigarettes, small cigars and roll-your-own tobacco

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The court here framed Central Hudson as providing that states can regulate speech that is merely potentially misleading if the government (1) has a substantial state interest in regulating the speech, (2) the regulation directly and materially advances that interest, and (3) the regulation is no more extensive than necessary to serve the interest