Nixon v. Shrink Missouri Government PAC, 528 U.S. 377 (2000)

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certiorari to the united states court of appeals for the eighth circuit

No. 98-963. Argued October 5, 1999—Decided January 24, 2000

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 (per curiam), the court found adequate support for the law in the proposition that large contributions raise 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. It ruled that the State's evidence was inadequate for this purpose.

Held: Buckley is authority for comparable state limits on contributions to state political candidates, and those limits need not be pegged to the precise dollar amounts approved in Buckley. Pp. 385-398.

(a) The Buckley Court held, inter alia, that a Federal Election Campaign Act provision placing a $1,000 annual ceiling on independent expenditures linked to specific candidates for federal office infringed speech and association guarantees of the First Amendment and the


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