Home › Case briefs › Constitutional Law

Nixon v. Shrink Missouri Government PAC

Supreme Court of the United States · 2000 · Constitutional Law

Constitutional LawFirst AmendmentCampaign Financecampaign contributionsFirst Amendmentpolitical associationspeechcorruption

Facts

Missouri enacted contribution limits for candidates for state office, including a limit of $1,000 per election for contributions to candidates for certain statewide offices, with biennial inflation adjustments. When suit was filed, the statewide-office limit was $1,075. Shrink Missouri Government PAC contributed $1,025 to Zev David Fredman's campaign for state auditor in 1997 and another $50 in 1998, and alleged it would give more absent the cap; Fredman alleged he could campaign effectively only with more generous contributions. Missouri defended the law as aimed at preventing corruption and the appearance of corruption from large contributions.

Issue

Whether Buckley v. Valeo authorizes states to impose limits on contributions to state political candidates, and whether Missouri's contribution limits violate the First Amendment because they are not supported by sufficient evidence or because they are lower in real dollars than the federal limits upheld in Buckley.

Rule

Under Buckley, contribution limits that significantly interfere with associational rights are constitutional if they are closely drawn to match a sufficiently important interest. Preventing corruption and the appearance of corruption is such an interest, and a state need not peg its contribution limits to Buckley's 1976 dollar figures so long as the limits are not so low as to prevent candidates from amassing the resources necessary for effective advocacy.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Oregon enacts a law capping individual contributions to candidates for secretary of state at $1,200 per election. In a suit filed in Portland, donor Elena Park and candidate Marcus Dole argue the cap must survive strict scrutiny because campaign fundraising affects political expression.

What standard should the court apply to evaluate the constitutionality of the contribution cap?

Explanation. The majority held that contribution limits are not reviewed under strict scrutiny. Because contribution limits impose only a marginal restraint on speech and a lesser burden on association than expenditure limits, they are evaluated under Buckley’s contribution-limit standard: whether the law is closely drawn to match a sufficiently important interest.