Iowa Right To Life Committee v. Megan Tooker, 717 F.3d 576

IRTL challenges Iowa campaign-finance laws, an admin rule, and two forms as applied to it; district court found lack of standing on several provisions but upheld others.
Post-Citizens United, Iowa amended its laws; IRTL sought a preliminary injunction and summary judgment before the 2010 election.
IRTL’s four-count complaint alleges: (1) definitions of ‘political committee’ and ‘permanent organization’ violate First Amendment; (2) PAC-like disclosure burdens; (3) ban on direct corporate contributions; (4) board-authorization and officer-certification requirements.
Iowa Supreme Court answered certified questions: independent expenditure committees vs PAC/permanent organization; held an independent expenditure committee status for such expenditures.
The district court held IRTL lacked standing on Counts 1 and some aspects of Counts 2–4; this court affirms in part, reverses in part, and remands.
On appeal, the court ultimately holds certain disclosure requirements constitutional as applied to non-PAC groups; other provisions, including ongoing and supplemental reporting and the certification/termination scheme, are unconstitutional as applied; severability is remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge definitions	IRTL asserts Buckley major-purpose concerns apply to it, avoiding PAC status.	Iowa Supreme Court’s ruling and record show no standing; definitions do not apply to IRTL.	IRTL lacks standing for Count 1
Constitutionality of disclosure as applied	Disclosure burdens on non-PAC groups are PAC-like and unconstitutional.	Disclosures advance informational interests and are permissible under exacting or strict scrutiny as appropriate.	Some disclosure provisions constitutional as applied; others unconstitutional as applied (Counts 2, Part)
Direct corporate contributions ban	Ban infringes First and Fourteenth Amendments; inconsistent treatment not justified.	Beaumont and MCCL support constitutionality; anti-corruption interest adequate.	Count 3 constitutional (facially and as applied)
Board-authorization and officer-certification requirements	Unconstitutional as applied; chill on corporate speech; unequal treatment under Fourteenth Amendment.	Regulations constitutional; not narrowly tailored; interests valid.	Count 4 unconstitutional as applied; severability remanded
severability and remand scope	Constitutional portions should be severed where unconstitutional.	Severability depends on district court’s analysis post-remand.	Remand to address severability

Buckley v. Valeo, 424 U.S. 1 (1976) (major-purpose and disclosure framework central to analysis)
Citizens United v. FEC, 558 U.S. 310 (2010) (distinction between disclosure requirements and restrictions on spending)
Minnesota Citizens Concerned for Life v. Swanson, 692 F.3d 864 (8th Cir. 2012) (en banc; ongoing reporting burdens evaluated for non-PAC groups)
NRLPAC v. Connor, 323 F.3d 684 (8th Cir. 2003) (standing and injury-in-fact considerations in campaign-finance challenges)
Kelley v. MCCL, 427 F.3d 1106 (8th Cir. 2005) (standing where groups engage only in pure issue advocacy; major purpose)
Reed v. Doe, 130 S. Ct. 2811 (2010) (distinction between facial and as-applied challenges; broad applicability)
Beaumont v. FEC, 539 U.S. 146 (2003) (direct corporate-contribution ban upheld under less-than-strict scrutiny)
Colorado Right to Life v. Coffman, 498 F.3d 1137 (10th Cir. 2007) (limits of major-purpose test for PAC-like status)
St. Paul Area Chamber of Commerce v. Gaertner, 439 F.3d 481 (8th Cir. 2006) (standing and injury-in-fact standards for challenges)