United States v. Danielczyk
2011 U.S. Dist. LEXIS 60918
E.D. Va.2011Background
- Defendants Danielczyk and Biagi coordinated Galen Capital Group/Corp contributions.
- Indictment Count Four charged directing corporate money to Hillary Clinton's 2008 campaign.
- Court previously dismissed Count Four under Citizens United as to direct corporate contributions.
- Court reconsidered in light of FEC v. Beaumont and Agostini v. Felton; government motion for reconsideration.
- Court held Beaumont not directly controlling for for-profit Galen; Citizens United requires equal corporate and individual speech.
- Court denied the government’s reconsideration to reinstate Count Four and Paragraph 10(b), but clarified the ban is unconstitutional as applied to this case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Beaumont controls this case. | Beaumont applies, upholding § 441b against nonprofits. | Beaumont does not directly control for Galen (for-profit). | Beaumont not directly controlling. |
| Whether Citizens United bars direct corporate contributions as applied here. | Citizens United requires equal rights for corporations and individuals. | Distinguish between independent expenditures and direct contributions; Beaumont persists. | Citizens United requires equal rights; 441b(a) unconstitutional as applied. |
| Whether the court should reinstate Count Four and Paragraph 10(b). | Reinstatement consistent with controlling precedent. | Beaumont and prior ruling should guide outcome. | Denied; Count Four/10(b) remains dismissed (with clarification). |
| What is the scope of the court’s holding after reconsideration. | Broadly constitutional as to all corporate donations. | Limited to this case's facts. | 2 U.S.C. § 441b(a) unconstitutional as applied to this case; limited holding. |
Key Cases Cited
- Buckley v. Valeo, 424 U.S. 1 (1976) (established direct/indirect expenditure distinctions; upheld direct contribution limits.)
- First National Bank of Boston v. Bellotti, 435 U.S. 765 (1978) (corporate identity not a barrier to speech.)
- Citizens United v. FEC, 130 S. Ct. 876 (2010) (struck down independent corporate expenditures ban; equal corporate speech rights.)
- FEC v. Beaumont, 539 U.S. 146 (2003) (limited, as-applied holding to nonprofit advocacy corporations.)
- Ashwander v. Tennessee Valley Authority, 297 U.S. 288 (1936) (prudential avoidance/constitutional rulings.)
- Agostini v. Felton, 521 U.S. 203 (1997) (overruling/limiting earlier precedents when appropriate.)