Facts
- Vermont enacted Act 64 (1997), regulating state election campaign finance.
- The law imposed mandatory candidate expenditure limits over the election cycle.
- The law imposed contribution limits of about 400 per candidate per election cycle for individuals, political committees, and political parties.
- Party contributions to a gubernatorial candidate were capped at $400 in the aggregate across national, state, and local party entities.
- The statute treated political parties similarly to individuals under the same low ceilings and counted certain volunteer-related expenses against contribution limits.
- Candidates, contributors, political parties, and committees challenged Act 64 under the First Amendment (as applied to the States through the Fourteenth Amendment).
- The district court invalidated the expenditure limits and certain party limits but upheld most other contribution limits.
- The court of appeals upheld all contribution limits and suggested the expenditure limits might be valid, remanding for a tailoring analysis.
- The Supreme Court granted review and addressed the constitutionality of both expenditure and contribution limits.
Issues
- Whether mandatory limits on candidate campaign expenditures violate the First Amendment.
- Whether Vermont’s 400 per-cycle contribution limits are so low, and structured in ways affecting parties and volunteers, that they violate the First Amendment.
Decision
- The Supreme Court reversed and remanded, holding both the expenditure limits and the contribution limits unconstitutional.
- The Court reaffirmed that mandatory candidate expenditure caps are invalid under controlling precedent.
- The Court held that contribution limits may be unconstitutional when set so low, and applied so broadly, that they materially burden effective campaigning and political association.
- A plurality identified multiple features of Act 64 indicating the limits were too restrictive, including their exceptionally low amounts, their application to political parties, and their treatment of volunteer-related spending.
Legal Principles
- Mandatory limits on campaign expenditures impose direct and severe restraints on political expression and generally cannot be sustained under the First Amendment.
- Contribution limits are subject to a less demanding standard than expenditure limits and may be justified by the interest in preventing corruption and the appearance of corruption.
- Contribution limits become unconstitutional when they are set so low, or structured so restrictively (including with respect to parties and volunteer activity), that they inhibit political discussion and impede candidates’ ability to mount effective campaigns.
- A government may not rely on generalized interests such as reducing the time candidates spend fundraising to justify restrictions foreclosed by controlling First Amendment doctrine.
Conclusion
The Court invalidated Vermont’s campaign finance regime because it imposed unconstitutional mandatory spending caps and contribution limits so low and broadly applied that they threatened effective advocacy and political association protected by the First Amendment.