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Under Buckley's standard of scrutiny, a contribution limit involving "significant interference" with associational rights may survive if the government demonstrates that contribution regulation is "closely drawn" to match a "sufficiently important interest," though the dollar amount of the limit need not be "fine tuned."
Respondents Shrink Missouri Government PAC, a political action committee, and Zev David Fredman, a candidate for the 1998 Republican nomination for Missouri state auditor, filed suit, alleging that a Missouri statute imposing limits ranging from $ 275 to $ 1,075 on contributions to candidates for state office violated their First and Fourteenth Amendment rights. Shrink Missouri gave Fredman $ 1,025 in 1997, and $ 50 in 1998, and represented that, without the statutory limitation, it would contribute more. Fredman alleged he could campaign effectively only with more generous contributions than the statute allowed. On cross-motions for summary judgment, the District Court sustained the statute. Applying Buckley v. Valeo, 424 U.S. 1, 46 L. Ed. 2d 659, 96 S. Ct. 612, the court found adequate support for the law in the proposition that large contributions raised suspicions of influence peddling tending to undermine citizens' confidence in government integrity. The court rejected respondents' 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 Eighth Circuit found that Buckley had articulated and applied a strict scrutiny standard of review, and held that Missouri had to demonstrate that it had a compelling interest and that the contribution limits at issue were narrowly drawn to serve that interest. Treating Missouri's claim of a compelling interest in avoiding the corruption or the perception of corruption caused by candidates' acceptance of large campaign contributions as insufficient by itself to satisfy strict scrutiny, the court required demonstrable evidence that genuine problems resulted from contributions in amounts greater than the statutory limits. A writ of certiorari was granted.
Did the state statute, which limited campaign contributions for state political candidates, violate the First Amendment?
On certiorari, the Supreme Court reversed the Court of appeals’ judgment and remanded the case for further proceedings. The Court held that state limits may--consistent with the First Amendment--be placed on contributions to state political candidates, where such state regulation was comparable to the federal regulation of federal campaign contributions approved in Buckley v Valeo. According to the Court, the state statute in question was not void under the First Amendment for want of evidence to justify the statute's limits, as the evidence was enough to show that the substantiation of the congressional concerns reflected in Buckley v Valeo with respect to federal contribution limits had a counterpart that supported the state statute. The Court noted that the evidence before the court of appeals described public revelations by the parties in question more than sufficient to show why voters would tend to identify a big donation with a corrupt purpose. Moreover, the state statute's contribution limits were not so different in kind from the federal limits upheld in Buckley v Valeo as to raise a First Amendment issue about the adequacy of the state statute's tailoring to serve the state statute's purposes, for there was no showing that the limitations had prevented candidates and political committees from amassing the resources necessary for effective advocacy.