A provision of the Federal Election Campaign Act of 1971, 86 Stat. 3, amended by 88 Stat. 1263, for expenditure ceilings imposes direct and substantial restraints on the quantity of political speech. A primary effect of the expenditure limitations is to restrict the quantity of campaign speech by individuals, groups, and candidates. The restrictions, while neutral as to the ideas expressed, limit political expression at the core of the electoral process and of the First Amendment freedoms.
Plaintiffs, candidates, contributors, political parties, and others, brought suit against defendant government officials, in their official capacity and as members of the Federal Election Commission. Plaintiffs challenged the constitutionality of the Act, related Tax Code provisions, and the validity of the Commission. The court of appeals upheld the Act. The court affirmed the decision as to the government interest in restricting influences stemming from the dependence of candidates on large campaign contributions, but the Court reversed the finding as to the expenditure ceilings and deemed them to be unconstitutional.
Did the contested Act contain unconstitutional provisions?
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 thatU.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.