Facts
- Federal candidates, parties, and political committees challenged provisions of the Federal Election Campaign Act of 1971, as amended in 1974, and related tax provisions regulating federal campaign finance.
- The challenged provisions set dollar limits on contributions to federal candidates and political committees, including aggregate limits on an individual’s total contributions.
- The law also limited independent expenditures made “relative to a clearly identified candidate,” capped overall campaign spending, and restricted candidates’ spending from personal or family resources.
- The law imposed disclosure and reporting duties on political committees and certain persons or groups making contributions or expenditures above specified thresholds.
- The 1974 amendments created the Federal Election Commission with rulemaking, adjudicatory, and enforcement authority, and provided for appointment of six voting commissioners by congressional officers and the President.
- Subtitle H of the Internal Revenue Code established a voluntary public financing system for presidential primaries, conventions, and general elections, with different funding levels for major, minor, and new parties.
- Plaintiffs sought declaratory and injunctive relief, asserting violations of the First and Fifth Amendments and the Appointments Clause; the case reached the Supreme Court on direct appeal.
Issues
- Whether limits on campaign contributions and expenditures violate the First Amendment rights of political speech and association.
- Whether disclosure and reporting requirements for campaign money are constitutional given burdens on associational privacy.
- Whether the statutory method of appointing Federal Election Commission voting members violates the Appointments Clause.
- Whether the presidential public financing scheme, including differing treatment of parties based on prior vote share, is constitutional.
Decision
- Upheld limits on contributions to candidates and political committees, including aggregate limits on an individual’s total contributions, as sufficiently related to preventing actual and apparent quid pro quo corruption.
- Struck down limits on independent expenditures, overall campaign expenditure ceilings, and limits on candidates’ expenditures from personal funds as unconstitutional restraints on political expression.
- Largely upheld disclosure and reporting requirements under “exacting scrutiny,” while allowing as-applied relief where a group shows a reasonable probability of threats, harassment, or reprisals.
- Held unconstitutional the method of appointing the FEC’s voting commissioners because the Commission exercised significant executive powers and its officers had to be appointed in conformity with Article II.
- Upheld the basic structure of presidential public financing and its eligibility distinctions among major, minor, and new parties as constitutionally permissible within a voluntary system.
Legal Principles
- Restrictions on political expenditures generally operate as direct restraints on political expression because limiting spending limits the amount and reach of campaign communication.
- Preventing quid pro quo corruption and its appearance is a permissible and weighty governmental interest in regulating campaign finance; “equalizing” relative political influence is not a valid First Amendment justification for suppressing speech.
- Contribution limits may be sustained because they are treated as a lesser burden on expression and association, regulating the size of financial support rather than directly restricting political advocacy.
- Independent expenditures made without coordination with a candidate present a reduced risk of quid pro quo corruption, weakening the justification for expenditure ceilings.
- Compelled disclosure in campaign finance is reviewed under exacting scrutiny and requires a substantial relation to sufficiently important interests, including informing voters, deterring corruption, and enabling enforcement.
- When a regulatory commission exercises substantial rulemaking, adjudicatory, and enforcement authority, its principal officers must be appointed in conformity with the Appointments Clause, and Congress may not reserve to itself appointment power inconsistent with Article II.
- A voluntary presidential public financing program may condition receipt of funds on compliance with spending limits, and Congress may use prior electoral support as an eligibility measure for allocating public funds.
Conclusion
The Court drew a constitutional line between contributions and expenditures: it sustained contribution limits, most disclosure requirements, and voluntary presidential public financing to prevent corruption and inform voters, but invalidated expenditure caps as direct limits on political speech and required the election commission’s principal officers to be appointed under Article II.