Facts
- The Federal Election Campaign Act (FECA) imposes recordkeeping and public disclosure duties on “political committees” that meet statutory thresholds for contributions or expenditures made to influence federal elections.
- James E. Akins and other registered voters filed an administrative complaint with the Federal Election Commission (FEC) alleging that the American Israel Public Affairs Committee (AIPAC) qualified as a “political committee” and therefore had to disclose donors and expenditures.
- The FEC found AIPAC engaged in certain communications outside FECA’s “membership communications” exception but dismissed the complaint, concluding AIPAC was not a “political committee” because its “major purpose” was lobbying on issues rather than nominating or electing candidates.
- The district court granted summary judgment to the FEC.
- The D.C. Circuit, sitting en banc, reversed, holding the FEC’s “major purpose” approach improperly interpreted FECA’s “political committee” definition.
- The Supreme Court granted certiorari to address standing and, if necessary, the validity of the “major purpose” approach.
Issues
- Whether voters who claim they were denied information that FECA requires to be publicly disclosed have Article III and statutory standing to seek judicial review of the FEC’s dismissal of their administrative complaint.
- Whether an organization falls outside FECA’s definition of “political committee” because its “major purpose” is not the nomination or election of candidates.
Decision
- The Supreme Court held that the respondents had standing to challenge the FEC’s dismissal.
- The Court concluded that respondents’ alleged inability to obtain donor and expenditure information they claimed FECA required to be disclosed constituted an “injury in fact.”
- The Court rejected the view that the injury was nonjusticiable merely because many members of the public could share it.
- The Court found causation and redressability satisfied because the FEC’s dismissal permitted AIPAC to avoid political-committee disclosure duties, and judicial relief setting aside the dismissal could lead to the sought disclosures.
- The Court did not decide the merits of whether the FEC’s “major purpose” test was a valid interpretation of FECA and left that question for further proceedings.
Legal Principles
- Congress may create a statutory right to information, and denial of information that a statute requires to be publicly disclosed can constitute Article III injury in fact.
- An injury may be concrete even if widely shared; broad public impact does not, by itself, defeat standing when the plaintiff alleges deprivation of a statutory informational entitlement.
- For standing, causation may be established where an agency nonenforcement dismissal enables an entity to avoid disclosure duties, and redressability may be satisfied where setting aside the dismissal can reasonably lead to obtaining at least some of the requested information.
- FECA’s authorization of judicial review by an “aggrieved” party supports broad access to court for complainants seeking review of an FEC dismissal.
Conclusion
The Court recognized voter standing to obtain judicial review of an FEC dismissal when the asserted harm is the loss of statutorily required campaign-finance information, while leaving unresolved the substantive question of how FECA’s “political committee” definition applies to an issue-oriented organization.