Buckley v. Valeo

Brief Fact Summary.

In an attempt to reduce corruption in political campaigns, Congress enacted several restrictions in financial contributions to candidates. The law limited the amount of money an individual could contribute to a single campaign to $1000 (“contribution limit”). The law also implemented limits on independent expenditures (“expenditure limit”).

Synopsis of Rule of Law.

In regards to campaign finance, the government may impose certain contribution limits. However, expenditure limits are unconstitutional.

Facts.

In part due to the Watergate scandal, Congress attempted to reduce corruption in political campaigns by restricting financial contributions to candidates. The law limited the amount of money an individual could contribute to a single campaign to $1000 (“contribution limit”). The law also implemented limits on independent expenditures (i.e., expenditures by other groups or individuals than candidates and political parties) (“expenditure limit”).

Issue.

Do the campaign finance laws at issue violate the First Amendment‘s freedom of speech and association clauses?

Held.

Yes and no – the contribution limits are constitutional, but the expenditure limits are unconstitutional.

Dissent.

Justice White

Justice White agreed with the Court’s judgment upholding the contribution limit. However, he disagreed with the Court’s view that the expenditure limits violate the First Amendment. He reasoned that it makes little sense to limit the amounts an individual may give to a candidate or spend with his approval but fail to limit the amounts that can be spent on his/her behalf.

Discussion.

The law’s contribution and expenditure limitations both implicate fundamental First Amendment interests. However, its expenditure limit impose significantly more severe restrictions on protected freedoms of political expression and association than do its limits on financial contributions. The contribution limit does not violate the First Amendment because the $1000 limit enhances the integrity of our democratic system by preventing unscrupulous practices. However, the expenditure limit limits expenditure from candidates’ own personal or family resources, which violates the First Amendment. The expenditure limit contravenes the First Amendment‘s provision on freedom of speech because a restriction on spending for political communication reduces the quantity of expression. Additionally, the expenditure limit does not necessarily increase the chance for corruption that individual contributions to candidates do; thus, restricting them does not serve a government interest great enough to warrant a limit on free speech and association.