Randall v. Sorrell

Background

Vermont passed Act 64 in 1997, imposing strict caps on what candidates may spend and on what individuals, parties, and groups may give. Examples in the law included roughly $300,000 for a governor’s two-year campaign and contribution caps of $400 for statewide candidates, $300 for state senate, and $200 for state house races. A group of candidates, voters, and political committees sued state officials to block enforcement. The District Court struck down the spending caps as violating the First Amendment and invalidated party contribution limits while upholding other contribution ceilings. The Court of Appeals upheld the contribution limits and remanded the question of whether the spending caps were narrowly tailored.

Reasoning

The Supreme Court reviewed whether Vermont’s spending and contribution ceilings survive the First Amendment. Applying Buckley v. Valeo, the Court held that candidate spending caps directly limit political expression and therefore violate Buckley’s rule. It also found the Act’s contribution limits unconstitutional because they were unusually low and not carefully tailored: they apply per two-year cycle, bind parties and volunteers in the same low amounts, and are not indexed for inflation. On that basis the Court concluded both the expenditure caps and the contribution scheme fail constitutional review.

Real world impact

The decision prevents Vermont from enforcing Act 64 as written. Candidates, political parties, campaign volunteers, and small donors will not be bound by these particular limits while the State considers replacements. The State Legislature may redraw its rules to address the Court’s concerns and the cases were sent back for further proceedings.

Dissents or concurrances

Some Justices dissented or concurred in part: two Justices argued the Court should not foreclose spending limits and would have allowed further fact-finding on tailoring; others joined the judgment but wrote separate opinions.