Buckley v. Valeo
Headline: Upheld federal limits on campaign contributions and disclosure, struck down limits on independent spending and candidates' personal and overall campaign spending, and limited the current Federal Election Commission's enforcement authority.
Holding:
- Keeps contribution limits and public reporting for donors and candidates.
- Allows unlimited independent political spending and candidates' personal spending.
- Requires Congress to fix or reappoint the Federal Election Commission quickly.
Summary
Background
A group of people and organizations challenging the 1974 changes to the Federal Election Campaign Act included a presidential candidate, a U.S. senator seeking re-election, political parties, minor parties, advocacy groups, and individual donors. The law set dollar caps on contributions, placed spending limits on candidates and independent groups, required public reporting and disclosure, created public funding for Presidential contests, and created a new Federal Election Commission (FEC) to run and enforce the system.
Reasoning
The Court separated contribution limits from spending limits. It found limits on individual contributions ($1,000 per candidate per election, $25,000 per year, and higher ceilings for registered political committees) and the Act’s reporting and disclosure rules justified by the government’s interest in preventing corruption and the appearance of corruption. By contrast the Court held that caps on independent expenditures, limits on a candidate’s personal spending, and overall campaign spending ceilings unduly restrict core political speech and are unconstitutional. The public financing rules were upheld as a valid use of congressional power and severable from invalid provisions. The Court also held that many strong enforcement and litigation powers given to the new FEC can be exercised only by federal officers appointed under the Constitution, so the Commission as constituted cannot validly exercise those powers.
Real world impact
Individuals and groups still face contribution limits and must follow disclosure rules, but independent political spending and candidates’ use of personal funds are not capped under the Court’s ruling. Public Presidential funding remains available under the statute, but Congress and the FEC will need to adjust enforcement structures. The Court stayed its ruling about the FEC’s authority for up to 30 days to allow Congress to respond.
Dissents or concurrances
At the Court of Appeals level some judges dissented about the appointment and separation-of-powers issues; the Supreme Court opinion notes that views differed over the FEC’s constitutionality and that one Justice took no part.
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