Nixon v. Shrink Missouri Government PAC (2000)
Shrink Missouri Government, a political action committee, and Zev David Fredman, a candidate for State office, sued Missouri's Attorney General, Jeremiah J. Nixon, challenging the constitutionality of a Missouri law that limited contributions to candidates for political office. The plaintiffs lost in the district court, but won at the Court of Appeals. The case then went to the Supreme Court.
In a 6-3 decision, the Supreme Court upheld Missouri's limits on contributions to candidates for State office.
Justice David Souter wrote the majority opinion. In Buckley v. Valeo, 1976, the Court had ruled that federal limits on contributions to candidates for federal office did not violate the speech and association provisions of the First Amendment. The main issue in Nixon v. Shrink Missouri Government was whether the reasoning in Buckley also applied to State campaign limits. Justice Souter noted that “there is little reason to doubt that sometimes large contributions will work actual corruption of our political system, and no reason to question the existence of a corresponding suspicion among voters.” There was no real evidence that the campaign contribution limits prevented candidates from raising enough money to communicate their messages to the voters.
Dissenting, Justice Anthony Kennedy criticized the Court “for announcing a rule that suppresses one of our most essential and prevalent forms of political speech.” He argued that the majority had failed to recognize the harm created by the ruling in Buckley. Buckley limited direct contributions to political candidates in federal elections without restricting the amount of “soft money” that political parties or interest groups could spend to support or attack a candidate's positions. This system gives great advantage to candidates who have the backing of established parties and support groups.
Congress created the Federal Election Commission (FEC) in 1975 to administer and enforce the Federal Election Campaign Act (FECA). Part of the FEC's duties are to monitor compliance with FECA's limits and restrictions on contributions to federal campaigns.
Buckley v. Valeo, decided in 1976, was the Supreme Court's first consideration of the FECA's campaign contribution limits. Buckley's basic ruling was that Congress can limit federal campaign contributions, but cannot limit spending by the candidates or their campaigns.
Nixon was the Supreme Court's first decision on campaign contribution limits in over twenty years. When Nixon was argued, thirty-five States had limits on the amount an individual could contribute to a candidate running for State office. The Eighth Circuit Court of Appeals ruled that Missouri had not shown sufficient problems with corruption or influence-buying to justify imposing the contribution limit. If the Supreme Court had adopted the Eighth Circuit's reasoning, the constitutionality of campaign contribution restrictions in all other States would have been in doubt.
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