Buckley v. Valeo Case Brief

Facts of the case

In the wake of the Watergate affair, Congress attempted to ferret out corruption in political campaigns by restricting financial contributions to candidates. Among other things, the law set limits on the amount of money an individual could contribute to a single campaign and it required reporting of contributions above a certain threshold amount. The Federal Election Commission was created to enforce the statute.

Why is the case important?

The Federal Election Campaign Act of 1971 (Act), as amended in 1974, created an eight-member Federal Election Commission (Commission) and vested in it wide-ranging rulemaking and enforcement powers for administering the Act. A separation of powers challenge was brought that Congress was precluded from vesting in itself the authority to appoint members of the Commission.

Question

Whether limiting contributions to political campaigns is constitutional?
Whether limiting expenditures in political campaigns is constitutional?

ANSWER

No. The provisions of the Act which vested in the Commission primary responsibilities for conducting civil litigation in the courts of United States for vindicating public rights violated Article II, Section:2, cl. 2, of the Constitution. Those administrative functions may only be performed by persons who are Officers of the United States. Dissent. None. Concurrence. None.

CONCLUSION

The Court found that the individual and political committee contribution limits, the disclosure and reporting provisions, and the public financing scheme were justified by weighty interests in restricting influences stemming from the dependence of candidates on large campaign contributions. The Court held, however, that the limitations on campaign expenditures were unconstitutional because they placed substantial and direct restrictions on the ability of candidates, citizens, and associations to engage in political expression that was protected by the First Amendment . The Court found that U.S. Const. art. II, § 2, cl. 2 , required that most of the powers conferred by the Act upon the Commission could be exercised only by officers of the United States. The court held that the Commission’s present membership was invalid.

  • Advocates: Brice M. Clagett Argued the cause for the appellants Lloyd N. Cutler Argued the cause for the appellees Archibald Cox Argued the cause for the appellees Ralph S. Spritzer Argued the cause for the appellees Daniel M. Friedman Argued the cause for the appellees Joel M. Gora Argued the cause for the appellants Ralph K. Winter, Jr.
  • Appellant: Buckley
  • Appellee: Valeo
  • DECIDED BY:Burger Court
  • Location: Congress
Citation: 424 US 1 (1976)
Argued: Nov 10, 1975
Decided: Jan 30, 1976
Buckley v. Valeo Case Brief