Nixon v. Shrink PAC
On January 24, 2000, the Supreme Court issued a ruling reaffirming the distinction set out in Buckley v. Valeo between expenditures and contributions, and upholding the constitutionality of contribution limits. Furthermore, the Court rejected the argument that the Missouri government was required to provide concrete evidence substantiating a need for limits to curtail corruption or the appearance of corruption. The Court concluded that the threat of corruption, and public concern about that threat, were sufficient.
Shrink Missouri Government PAC (Shrink PAC) and Zev David Fredman, a candidate for Missouri 's Republican nomination for state auditor in 1998, filed suit alleging that Missouri contribution limits (ranging from $275 to $1075 to candidates for state office) violated their First and Fourteenth Amendment rights. The district court, relying on Buckley v. Valeo, sustained the statute in a summary judgment, finding that limits on political contributions were based on the belief that large contributions raise suspicions of influence peddling, which tend to undermine citizens' confidence in government integrity.
The district court rejected the respondents' claim that inflation since the Buckley decision had rendered the state limit unconstitutional today.
In reversing the district court's decision, the Eighth Circuit Court of Appeals held that Missouri had to demonstrate that it had a compelling interest and that the contribution limits at issue served that interest. Missouri claimed a compelling interest in avoiding corruption or the perception of corruption caused by large campaign contributions. The appeals court, however, found this insufficient and required Missouri to provide demonstrable evidence that genuine problems resulted from contributions that exceeded the statutory limits. It ruled that the state's evidence was inadequate for this purpose.
The Supreme Court, in its opinion delivered by Justice Souter, reversed the Eight Circuit's decision and held that Buckley v. Valeo, a 1976 Supreme Court decision, was the authority for comparable state limits on contributions to state political candidates.
The Buckley court struck down the Act's $1,000 limit on independent expenditures made by individuals on behalf of candidates for federal office, maintaining that the limits infringed upon the free speech and association guarantee of the First Amendment and the Equal Protection Clause of the Fourteenth. By contrast, the Buckley Court upheld provisions limiting individual contributions to a candidate to $1,000 per election. The Court drew a line between independent expenditures and contributions, treating expenditure restrictions as direct restraints on speech but saying, in effect, that limiting contributions to candidates did not violate an individual's right to free speech. The Buckley Court found the prevention of corruption and the appearance of corruption to be constitutionally sufficient justification for the contribution limits at issue.
In this case, the Supreme Court rejected the appeals court's requirement that the government demonstrate that corruption among public officials is real, and not merely conjectural. Acknowledging that conflicting academic studies both assert and deny that large contributions to candidates change candidates' positions, the Court concluded that there is little reason to doubt that sometimes large contributions will corrupt our political system and no reason to doubt a corresponding suspicion among voters.
Further, the Court found no support for the respondents' arguments that Missouri 's contribution limits were so different from those sustained in Buckley as to raise a new issue about the adequacy of the Missouri limits. In fact, the Court found no indication that contribution limits had a dramatic adverse effect on the funding of campaigns and political associations and, thus, no evidence that the limitations had prevented candidates from raising the resources necessary for effective advocacy.
Justice Stevens filed a concurring opinion. Justice Breyer filed a concurring opinion, in which Justice Ginsburg joined. Justice Kennedy filed a dissenting opinion. Justice Thomas also filed a dissenting opinion, in which Justice Scalia joined.
Source: FEC Record— March 2000. 120 S. Ct. 897 (2000).