Facts
- Missouri enacted statutory limits on contributions to candidates for state office, with caps varying by office and constituency size.
- For statewide office in 1998 (including State Auditor), the limit was $1,075 per election from any one donor.
- Shrink Missouri Government PAC contributed up to the legal limit to a candidate for Missouri State Auditor and asserted it would contribute more absent the cap.
- The candidate alleged he could campaign effectively only with contributions exceeding the statutory limit.
- Missouri justified the limits as a response to public concern that large donations create actual corruption or the appearance of corruption, supported by examples of large contributions and statements from officials about public suspicion of influence peddling.
Issues
- Whether the constitutional framework governing federal contribution limits also applies to state limits on contributions to state candidates.
- Whether the dollar amount sustained in prior federal precedent sets a constitutional benchmark (including by inflation adjustment) for permissible state contribution limits.
- Whether Missouri’s contribution limits violate the First and Fourteenth Amendments by unduly burdening political speech and association.
Decision
- The Supreme Court reversed the Eighth Circuit and upheld Missouri’s contribution limits.
- The Court held that precedent sustaining federal contribution limits is authority for comparable state limits on contributions to state political candidates.
- The Court rejected the view that contribution limits are subject to classic strict scrutiny requiring a compelling interest and narrow tailoring.
- The Court held the State need not prove specific instances of actual corruption at amounts just above the statutory caps to justify limits aimed at preventing corruption and its appearance.
- The Court found no record showing that the limits were so low as to make political association ineffective or prevent effective advocacy.
Legal Principles
- Contribution limits, unlike expenditure limits, are reviewed under a “closely drawn” standard requiring a sufficiently important governmental interest and avoidance of unnecessary abridgment of associational freedoms.
- Preventing corruption and the appearance of corruption is a sufficiently important interest that can justify contribution limits.
- A state is not required to produce specific empirical proof of actual corruption at the precise contribution levels it restricts; the evidentiary showing may vary with the plausibility of the justification and the context.
- The federal dollar figures sustained in earlier cases do not set a constitutional ceiling or floor for state contribution limits; states may choose different amounts if the limits do not impose a severe practical burden.
- A contribution limit becomes constitutionally suspect when it is so low in practical effect that it renders political association ineffective and makes contributions functionally pointless.
Conclusion
The Court held that Missouri’s campaign contribution limits were constitutional because they were closely drawn to serve the sufficiently important interest in preventing corruption and its appearance, and the First Amendment does not require states to match federal benchmark amounts or to prove actual corruption at marginally higher contribution levels.