Nixon v. Shrink Missouri Government PAC

PETITIONER: Nixon
RESPONDENT: Shrink Missouri Government PAC
LOCATION: Congress

DOCKET NO.: 98-963
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 528 US 377 (2000)
ARGUED: Oct 05, 1999
DECIDED: Jan 24, 2000

ADVOCATES:
D. Bruce La Pierre - Argued the cause for respondents
Jeremiah W. Nixon - Jefferson City, Missouri, argued the cause for petitioners
Seth P. Waxman - Argued the cause for the United States as amicus curiae, by special leave of court, in support of the petitioners

Facts of the case

In 1976, Buckley v. Valeo established a $1,000 cap on individuals' contributions to candidates for federal office. Missouri law imposes campaign contribution limits, ranging from $250 to $1,000, to candidates for state office. The statute allows for periodic adjustments, which increased the 1998 contribution limit to $1,075 for candidates for statewide office, including state auditor. In 1998, Zev David Fredman, a candidate for the Republican nomination for Missouri state auditor, and the Shrink Missouri Government PAC, a political action committee, filed suit, alleging that the Missouri statute imposing limits on contributions to candidates for state office violated their First and Fourteenth Amendment rights. The PAC had contributed $1,075 to Fredman and argued, without the limitation, it would contribute more to Fredman's campaign. Additionally, Fredman alleged he could campaign effectively only with more generous contributions. The Federal District Court, applying Buckley v. Valeo, upheld the statute. The court rejected Fredman's and the PAC's contention that inflation since Buckley's approval of a federal $1,000 restriction meant that the state limit of $1,075 for a statewide office could not be constitutional today. In reversing, the Court of Appeals, found that Missouri's interest in avoiding the corruption or the perception of corruption caused by candidates' acceptance of large campaign contributions was insufficient to satisfy Buckley's strict scrutiny standard of review.

Question

Does Buckley v. Valeo govern state regulations on contributions to state political candidates? Do the federal limits approved in Buckley, with or without adjustment for inflation, define the scope of permissible state limitations? Is Missouri's statutory limit on campaign contributions unconstitutional?

Media for Nixon v. Shrink Missouri Government PAC

Audio Transcription for Oral Argument - October 05, 1999 in Nixon v. Shrink Missouri Government PAC

Audio Transcription for Opinion Announcement - January 24, 2000 in Nixon v. Shrink Missouri Government PAC

John Paul Stevens:

Justice Souter has an opinion to announce.

David H. Souter:

I have the opinion to announce in Nixon v. Shrink Missouri Government PAC, No. 98-963.

This case comes to us on writ of certiorari to the Court of Appeals for the Eighth Circuit.

The suit in this case was brought by respondents Shrink Missouri Government PAC, a political action committee, and Fredman, a candidate for the 1998 Republican nomination for Missouri State Auditor.

They alleged that the First and Fourteenth Amendments were violated by a Missouri statute that imposes limits ranging from $275 to $1,075 on contributions to candidates for state offices.

The District Court sustained the statute but the Eighth Circuit reversed, holding that under our 1976 decision in Buckley v. Valeo, Missouri had failed to demonstrate a requisite compelling interest in the limits, it failed to make a necessary evidentiary showing of problems resulting from contributions in amounts in excess of those permitted by the statute, and it failed to show that the statute was closely enough tailored to serve the interest claimed by the state.

In an opinion filed with the Clerk today, we reverse.

Although, Buckley deals with federal contribution limits and federal candidates, it is authority for comparable state limits on contributions to state candidates.

Under Buckley a contribution limit involving significant interference with associational rights, survive scrutiny if the government demonstrates that regulating contributions is a means closely drawn to match an important interest.

The Missouri statute is adequately tied to an important state interest, Buckley found that the prevention of corruption and the appearance of corruption was a constitutionally sufficient justification for the contribution limits at issue, in that case, Missouri espouses the same interest and there can be no serious question about their legitimacy.

Likewise, the Missouri statute enjoys adequate evidentiary support which we cover in our opinion.

This case does not present a close call requiring further definition of a state's evidentiary obligation beyond what Buckley indicates.

Finally, there is no indication here that the Missouri limits have had an effective suppressing in the political speech necessary for an adequate campaign of workable political association, and thus there is no showing that the limitation prevented effective political advocacy.

Respondents argue that Buckley set a nominal minimum $1,000 constitutional threshold for contribution limits, which in dollars adjusted for loss of purchasing power is now well above even the $1,000 line drawn by Missouri.

This argument is a fundamental misunderstanding of Buckley.

There we specifically rejected the contention that $1,000, or any other particular amount was a constitutional minimum, instead we asked whether the contribution limitation was so low as to impede the ability of candidates to amass the resources necessary for effective advocacy.

Justice Stevens has filed a concurring opinion; Justice Breyer has filed a concurring opinion in which Justice Ginsburg joins; Justice Kennedy has filed a dissenting opinion; Justice Thomas has filed a dissenting opinion in which Justice Scalia joins.