Buckley v. Valeo

Brief Fact Summary. A Restriction on campaign finances was alleged to violate First Amendment of the United States Constitution’s (Constitution) freedom of speech.

Synopsis of Rule of Law. A restriction on the amount of money a person or group can spend on political communications during a campaign necessarily reduces the quantity of expression by restricting the number of issues discussed, the depth of their exploration and the size of the audience reached.

Facts. The statutory scheme adopted by Congress, the Federal Election Campaign Act of 1971 (the Act), to regulate federal election campaigns included restrictions on political contribution and expenditures that apply broadly to all phases of and all participants in the election process. The major contribution and expenditure limitations in the Act prohibit individuals from contributing more than 25,000 dollars in a single year or 1,000 dollars to any single candidate for an election campaign and from spending more than 1,000 a year relative to a clearly identified candidate. Other provisions of the Act restrict a candidate’s use of personal and family resources in his campaigning and limited the amount that could be spent by a candidate in campaigning for federal office.

Issue. Did the limits placed on electoral expenditures by the Act and related provisions of the Internal Revenue Code of 1954 (IRC), violate the First Amendment’s freedom of speech and association clauses?

Held. The provisions of the Act that impose a 1,000-dollar limitation on contributions are constitutionally valid. These limitations serve the basic governmental interest in safeguarding the integrity of the electoral process without directly impinging upon the rights of individual citizens and candidates to engage in political debate and discussion. However, the First Amendment of the Constitution requires the invalidation of the Act’s independent ceilings. These provisions place substantial and direct restrictions on the ability of the candidates, citizens and associations to engage in protected political expression. Limiting expenditures from a candidate from his own personal or family funds is unconstitutional and the interest in equalizing the relative financial resources of donations is not sufficient to justify the provisions infringement on First Amendment constitutional rights.

Dissent.
The Supreme Court of the United States’ (Supreme Court) attempt to distinguish the communication inherent in political contributions from the speech aspect of political expenditure will not wash. Contribution limits are a severe restriction on the First Amendment of the Contribution.
Expenditure limitations do not violate the First Amendment of the Constitution as Congress in enacting this bill wished to ensure that personal wealth and money ought to play a less important role in political campaigns

Discussion. This case involves the regulation of campaign finances within the context of the First Amendment of the Constitution. The type of speech restricted here was content-neutral, as it was not the content of the speech being restricted, rather the manner in which the speech was communicated. The campaign finance restrictions were meant to affect all candidates equally. The Supreme Court ruled that campaign finance could not be restricted under the First Amendment of the Constitution if it necessarily reduces the quantity of expression by restricting the number of issues discussed, the depth of their exploration and the size of the audience reached.