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Randall v. Sorrell

Supreme Court of the United States · 2006 · Constitutional Law

Constitutional LawFirst AmendmentCampaign FinanceFirst Amendmentcampaign expenditurescampaign contributionspolitical partiescareful tailoring

Facts

Vermont's Act 64 imposed mandatory expenditure caps on candidates for state office for a two-year election cycle and also set low contribution limits for individuals, organizations, and political parties. The contribution limits applied per election cycle and, in practice, amounted to very low per-election caps, including roughly $200 per election for gubernatorial candidates, with even lower limits for legislative races. The Act treated political parties under the same low caps as individuals and broadly counted coordinated party spending and certain volunteer-related expenses toward contribution limits. The statute also did not index contribution limits for inflation.

Issue

Whether Vermont's Act 64 violated the First Amendment by limiting how much candidates for state office could spend on their campaigns and by imposing very low contribution limits on individuals and political parties. More specifically, the Court considered whether Buckley controlled the expenditure limits and whether the contribution limits were so low and restrictive that they were not closely drawn to the State's anti-corruption interests.

Rule

Under Buckley v. Valeo, candidate expenditure limits violate the First Amendment because they impose severe restrictions on political expression and association. Contribution limits may be upheld only if they are closely drawn to match a sufficiently important governmental interest, such as preventing corruption or its appearance; when there are danger signs that limits are too low and too strict, courts must independently review the record to determine whether the statute's tailoring is proportionate to its objectives.

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

Ohio enacts a statute capping how much a candidate for governor may spend during the entire election season. The legislature says the cap is needed because candidates are spending too much time fundraising instead of meeting voters in Columbus, Cleveland, and Cincinnati.

A gubernatorial candidate challenges the spending cap under the First Amendment. What is the strongest answer?

Explanation. The majority held that candidate expenditure limits violate the First Amendment under Buckley and declined to overrule or significantly distinguish that rule. A state may not rescue an expenditure cap by arguing that it frees candidates from spending time fundraising; the Court treated that rationale as insufficient and not a meaningful basis for distinction. (Derived from Randall v. Sorrell (2006).)