Stop Reckless Economic Instability Caused By Democrats v. Federal Election Commission
93 F. Supp. 3d 466
E.D. Va.2015Background
- Plaintiffs (Stop PAC, Tea Party Leadership Fund, Alexandria Republican City Committee, and intervenor American Future) challenged FECA contribution limits: the six‑month registration rule for qualifying as a multicandidate PAC and various contribution ceilings to candidates and party committees.
- Stop PAC and American Future registered shortly before 2014 elections and say the six‑month rule forced them to make only $2,600 contributions (rather than $5,000) to certain candidates, injuring their First and Fifth Amendment rights.
- The Fund (Tea Party Leadership Fund) is a long‑standing multicandidate PAC that challenged lower annual contribution limits imposed on multicandidate PACs to national and state party committees compared to newly registered committees treated as "persons."
- Plaintiffs sought declaratory relief and a permanent injunction against FEC enforcement of the challenged provisions. The FEC moved for summary judgment; the court assumed standing and avoided mootness dispositions but reached the merits.
- The district court held that the challenged FECA provisions are constitutional and granted summary judgment to the FEC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the six‑month waiting period for multicandidate PAC status (2 U.S.C. § 441a(a)(4)) and resulting $2,600 cap as applied to new PACs violates the First Amendment | The waiting period and lower contribution cap suppress association/speech by preventing bigger, timely contributions in the pre‑election period | Contribution limits and waiting period impose only marginal burdens on First Amendment rights and leave other avenues of political expression open | Court upheld the waiting period; no First Amendment violation under Buckley/CMA framework |
| Whether the $2,600 per‑election limit on contributions from "persons" (including new PACs) to candidates violates the Fifth Amendment equal‑protection component as applied | New PACs (with >50 donors and contributions to 5+ candidates) are indistinguishable from established multicandidate PACs and thus discriminated against based on registration timing | New PACs and multicandidate PACs are not similarly situated; the classification combats circumvention and corruption risk, especially near elections | Court held PACs not similarly situated and rejected equal‑protection challenge; limit upheld |
| Whether annual limits on multicandidate PAC contributions to national ($15,000) and state ($5,000) party committees violate the Fifth Amendment | The Fund and ARCC claim these lower limits (versus higher limits for "persons") discriminatorily depress funds to party committees | Government interest in preventing corruption/circumvention justifies differential limits; multicandidate PACs differ in scale and risk profile | Court upheld the multicandidate PAC limits under equal‑protection analysis; claim denied |
Key Cases Cited
- Buckley v. Valeo, 424 U.S. 1 (1976) (upheld contribution limits as marginal restraints on First Amendment interests)
- California Medical Association v. FEC, 453 U.S. 182 (1981) (held contributor’s interests in PAC proxy speech receive reduced protection)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements: injury in fact, causation, redressability)
- FEC v. Wisconsin Right to Life, 551 U.S. 449 (2007) (capable‑of‑repetition‑yet‑evading‑review mootness exception in election cases)
- Nixon v. Shrink Missouri Government PAC, 528 U.S. 377 (2000) (upheld contribution limits and noted lower scrutiny for contribution regulations)