Buckley v. Valeo

Buckley v. Valeo, Supreme Court, 1976

Facts of the Case

In response to the Watergate scandal, Congress passed the Federal Election Campaign Act (FECA) of 1971 and its 1974 amendments, which imposed limits on campaign contributions and expenditures. The law also established the Federal Election Commission (FEC) to enforce these regulations. A group of plaintiffs, including Senator James L. Buckley, challenged the constitutionality of various provisions of FECA, arguing that they violated the First Amendment’s guarantee of freedom of speech and association.

Constitutional Question

  1. Do the limits on campaign contributions and expenditures imposed by FECA violate the First Amendment’s guarantees of freedom of speech and association?
  2. Is the method of appointing members to the FEC constitutional?

Arguments

For Buckley (the plaintiffs):

  • The limits on campaign expenditures restrict the ability of candidates and supporters to communicate political messages, thus violating the First Amendment.
  • Contribution limits infringe on the right to freely associate and support political candidates and causes.
  • The method of appointing FEC members, involving both Congress and the President, violates the separation of powers doctrine.

For Valeo (Secretary of the Senate and the FEC):

  • Contribution and expenditure limits are necessary to prevent corruption and the appearance of corruption in the political process.
  • The regulations ensure that candidates rely on a broader base of support rather than a few wealthy donors, promoting fairness in elections.
  • The FEC’s appointment structure is consistent with the Constitution’s provisions on the separation of powers and checks and balances.

The Decision

The Supreme Court issued a per curiam (unsigned) opinion, upholding some provisions of FECA while striking down others. The key rulings were:

  1. Contribution Limits: The Court upheld limits on individual contributions to political campaigns and candidates, recognizing that these limits help prevent corruption and the appearance of corruption. The Court found that such limits do not severely restrict political expression and are justified by the government’s interest in maintaining the integrity of the electoral process.
  2. Expenditure Limits: The Court struck down limits on independent expenditures (spending by individuals or groups not coordinated with a candidate’s campaign) and candidate personal expenditures, ruling that these limits violate the First Amendment. The Court held that expenditure limits impose significant restraints on political expression by restricting the ability of candidates and supporters to convey their messages.
  3. Disclosure and Reporting Requirements: The Court upheld requirements for disclosure of contributions and expenditures, finding that transparency in campaign financing serves important governmental interests in preventing corruption and providing voters with information about the sources of campaign funds.
  4. Federal Election Commission (FEC) Appointments: The Court found the method of appointing members to the FEC unconstitutional because it violated the Appointments Clause. The Court held that FEC members must be appointed in a manner consistent with the separation of powers.

Significance

Buckley v. Valeo is a landmark case in campaign finance law that established the constitutional framework for regulating political contributions and expenditures. The decision affirmed the principle that while the government can impose limits on contributions to prevent corruption, expenditure limits are more problematic as they directly impinge on free speech. The case highlighted the tension between efforts to regulate campaign finance and the protection of First Amendment rights. Buckley v. Valeo continues to influence campaign finance regulations and subsequent legal challenges, shaping the landscape of political campaign funding in the United States.