JEREMIAH W. (JAY) NIXON, ATTORNEY GENERAL OF MISSOURI, et al. v. SHRINK MISSOURI GOVERNMENT PAC et al.

Legal Principle at Issue

Whether the Buckley v. Valeodecision authorizes state limits on campaign-contributions to state political candidates. Whether the limits approved in Buckleydefine the scope of permissible state limitations.

Action

Reversed and remanded. Petitioning party received a favorable disposition.

Facts/Syllabus

In 1994 Missouri enacted a statute limiting contributions to candidates for state and local offices. Shrink Missouri Government PAC (a political action committee) and Zev David Fredman (a candidate for state auditor) sued the parties responsible for enforcing the statute, challenging its constitutionality. They claimed that the contribution limits violated their First Amendment free-speech rights and that Fredman could not run an effective campaign with the limits in place. The district court upheld Missouri's campaign-contribution limits. The court of appeals reversed the judgment of the district court and held that the Missouri campaign limits violate the First Amendment.

In Buckley, the Supreme Court struck down federal expenditure regulations as violating the First Amendment, but upheld contribution restrictions. The Respondents in this case claim that the State must justify the imposition of these limits by showing actual evidence of their claim that the absence of limits encourages corruption in the political process.

Importance of Case

In Buckley, the court found the prevention of both corruption and the appearance of corruption to be sufficient justification for contribution limits. Limits on contributions to candidates are less constitutionally suspect than direct limits on speech. The court reasons that money is property, not speech. While the right to use one's money to fund "speech by proxy" merits constitutional protection, property rights are not entitled to the same protection as speech rights.