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Missouri Republican Party v. Charles F. Lamb


On September 11, 2000, the U.S. Court of Appeals for the Eighth Circuit reversed the district court's judgment and ruled that Missouri 's limitations on political party contributions to candidates were unconstitutional. The court concluded that this case differed from the Buckley v. Valeo and Nixon v. Shrink Missouri Government PAC cases because it involved limits on contributions from a political party whereas the other two involved contributions from individuals.

In Buckley, the Supreme Court ruled that individual contribution limits were constitutional because they imposed "only a marginal restriction upon the contributor's ability to engage in free communication." The circumstances are different in this case, however, because the contributor is a political party, the court said. The court noted that the relationship between candidates and individuals is not nearly as close as that between candidates and parties. The identities of candidates and parties are often "virtually indistinguishable from each other." Whereas an individual can potentially corrupt a candidate with a contribution, parties and candidates have such "a unity of purpose" that the threat of corruption is "not a very realistic one." In addition, the court said that "a party's contribution provides an ideological endorsement and carries a philosophical imprimatur that an individual's contribution does not, and thus it cannot properly be called a 'contribution' in the same sense that the individual contributions in Buckley were."

The court also maintained that, in this case, there was no evidence that limiting parties' contributions would reduce corruption or measurably decrease the number and instances when individuals circumvented their own contribution limits. Finally, the court held that its ruling also applied to Missouri 's limits on party in-kind contributions.

Source:   FEC RecordNovember 2000. 227 F. 3d 1070 C.A., 8 (Mo.) 2000.