Nixon v. Shrink Missouri Government PAC
Headline: Campaign contribution limits upheld as constitutional under Buckley, allowing Missouri to enforce lower dollar caps and affecting candidates, donors, and state elections.
Holding: Buckley governs state contribution limits; the Court reversed the Eighth Circuit and held states may enforce comparable contribution caps not tied to Buckley’s dollar amounts.
- Allows states to enforce their own campaign contribution caps without matching Buckley dollars.
- Requires donors and candidates to follow state-set dollar limits.
- Encourages states to index limits and rely on local evidence of corruption concerns.
Summary
Background
Missouri enacted new limits on how much people and groups may give to state candidates, with amounts that ranged by office and were indexed for inflation. A political action committee and an outsider candidate sued, arguing the caps violated their First Amendment rights. A federal district court upheld the law, the Eighth Circuit struck it down, and the State appealed to this Court.
Reasoning
The Court addressed whether the 1976 Buckley v. Valeo decision supports state contribution limits and whether states must use Buckley’s dollar figures. Relying on Buckley, the Court held that states may adopt comparable contribution limits and that those limits need not be pegged to the exact dollar amounts used in Buckley. The Court explained that preventing corruption and the appearance of corruption is a legitimate interest and that Missouri presented sufficient evidence (legislative affidavit, newspaper reports, prior scandals, and overwhelming voter approval) to justify its limits under Buckley’s framework. The Court reversed the Eighth Circuit and sent the case back for further proceedings consistent with its opinion.
Real world impact
The ruling lets Missouri and other states keep or enact contribution caps similar in kind to the federal limits upheld in Buckley, without being required to match Buckley’s historical dollar amounts precisely. Donors and candidates must follow state dollar ceilings, and legislatures may index or revise caps over time. The decision is not a request for further national rulemaking; it applies Buckley’s approach to state law here.
Dissents or concurrances
Justices Stevens and Breyer agreed with the result but emphasized different points about money, property, and deference to legislatures. Justices Kennedy and Thomas dissented, arguing Buckley should be overruled and that contribution limits unduly suppress political speech and encourage “soft money.”
Opinions in this case:
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