Nixon v. Shrink Missouri Government PAC

Brief Fact Summary. A state statue limits individual political contributions.

Synopsis of Rule of Law. The danger of corruption by large dollar contributions is sufficiently plausible to satisfy heightened scrutiny of the First Amendment infringement.

Facts. The Missouri state statute limits the amount of individual political contributions from $250.00 to $1,000.00 depending upon the office and the size of the constituency. The state claims that its interest is in preventing corruption.

Issue. Are state limitations on political contributions for state political candidates constitutionally valid?

Held. Yes. The holding of Buckley still applies today.

Dissent.
Justice Kennedy: This decision has forced the development of covert speech and elaborate schemes to avoid the detection of contributions.
Justice Thomas: Campaign contribution limits should be subject to strict scrutiny.
Concurrence. The donation of money is a property right and not an exercise of free speech.

Discussion. No actual evidence of corruption need be present. The mere perception or suggestion that it is possible is sufficient to meet the governmental burden of a legitimate interest.