McConnell v. Federal Election Comm'n, 540 U.S. 93, 167 (2003)

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266

McCONNELL v. FEDERAL ELECTION COMM'N

Opinion of Thomas, J.

I

A

"[C]ampaign finance laws are subject to strict scrutiny," Federal Election Comm'n v. Beaumont, 539 U. S. 146, 164 (2003) (Thomas, J., dissenting), and thus Title I must satisfy that demanding standard even if it were (incorrectly) conceived of as nothing more than a contribution limitation. The defendants do not even attempt to defend Title I under this standard, and for good reason: The various restrictions imposed by Title I are much less narrowly tailored to target only corrupting or problematic donations than even the contribution limits in Shrink Missouri. See 528 U. S., at 427- 430 (Thomas, J., dissenting); see also Colorado Republican Federal Campaign Comm. v. Federal Election Comm'n, 518 U. S. 604, 641-644 (1996) (Colorado I) (Thomas, J., concurring in judgment and dissenting in part). And, as I have previously noted, it is unclear why "[b]ribery laws [that] bar precisely the quid pro quo arrangements that are targeted here" and "disclosure laws" are not "less restrictive means of addressing [the Government's] interest in curtailing corruption." Shrink Missouri, supra, at 428.

The joint opinion not only continues the errors of Buckley v. Valeo, by applying a low level of scrutiny to contribution ceilings, but also builds upon these errors by expanding the anticircumvention rationale beyond reason. Admittedly, exploitation of an anticircumvention concept has a long pedigree, going back at least to Buckley itself. Buckley upheld a $1,000 contribution ceiling as a way to combat both the "actuality and appearance of corruption." 424 U. S., at 26. The challengers in Buckley contended both that bribery laws represented "a less restrictive means of dealing with 'proven and suspected quid pro quo arrangements,' " id., at 27, and that the $1,000 contribution ceiling was overbroad as "most large contributors do not seek improper influence over a candidate's position or an officeholder's action," id., at 29. The

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