Nader v. Federal Election Commission
854 F. Supp. 2d 30
D.D.C.2012Background
- Ralph Nader, former presidential candidate, filed FECA-related claims against the Federal Election Commission (FEC).
- Nader’s administrative complaint (May 2008) alleged coordinated violations by Democratic Party-affiliated individuals, law firms, and groups in 2004 ballot access challenges.
- FEC unanimously dismissed the administrative complaint and closed most entities; Nader challenged the decision in this Court under 2 U.S.C. § 437g(a)(8).
- This Court granted the FEC’s summary judgment in November 2011, holding the agency’s decision not to find violations was not contrary to law, arbitrary, capricious, or an abuse of discretion.
- Nader filed a Rule 59(e) motion to alter or amend the judgment; the Court denied the motion after considering the record and controlling law.
- Judgment denying the motion was entered on April 12, 2012; the court reaffirmed its prior disposition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FEC’s failure to notify all respondents violated FECA and was harmless | Nader argues the error was not harmless and affected outcome | FEC’s notice failure qualifies as harmless under Club for Growth doctrine | Harmless error ruling affirmed; no reversal of FEC decision |
| Whether the court applied the correct evidentiary standard for FECA violations | Nader claims the court used an improper actual-proof standard | Court did not apply the wrong standard; reviewed under applicable law | Court correctly applied standard and deferential review to FEC's decision |
| Whether the court misconstructed or disregarded evidence in the administrative record | Nader asserts misstatements about coordination and evidence | Record interpreted consistently with FECA and deference to FEC findings | No clear error; evidence reasonably supported the ruling |
Key Cases Cited
- Fed. Election Comm'n v. Club for Growth, Inc., 432 F. Supp. 2d 87 (D.D.C. 2006) (harmless error doctrine applied to notification failures)
- Hagelin v. FEC, 411 F.3d 237 (D.C. Cir. 2005) (standard of review for FEC actions; deference to FEC findings)
- Niedermeier v. Office of Baucus, 153 F. Supp. 2d 23 (D.D.C. 2001) (Rule 59(e) standards for extraordinary relief)
- Anyanwutaku v. Moore, 151 F.3d 1053 (D.C. Cir. 1998) (intervening change or clear error standard for Rule 59(e))
- New York v. United States, 880 F. Supp. 37 (D.D.C. 1995) (principles governing reconsideration and reconsideration arguments)