United States v. Danielczyk
683 F.3d 611
4th Cir.2012Background
- Galen Capital Group officers Danielczyk (chairman) and Biagi (secretary) reimbursed Clinton donors $156,400 via checks labeled as consulting fees.
- They concealed reimbursements by inflating amounts, back-dating donor letters, and mischaracterizing payments to the donors.
- Indictment charged seven counts; count four and paragraph 10(b) alleged knowingly and willfully converting corporate funds to a federal candidate and conspiracy.
- District court granted motion to dismiss count four, holding §441b(a) unconstitutional as applied in light of Citizens United.
- Beaumont addressed direct corporate contributions ban for nonprofits and was considered for applicability post-Citizens United, leading the district court to reconsider but ultimately dismiss the charges.
- Fourth Circuit reversed, holding §441b(a) not unconstitutional as applied to Galen; Beaumont remains controlling for the direct-contributions ban; Citizens United does not overrule Beaumont regarding direct contributions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is §441b(a) unconstitutional as applied to Galen? | Danielczyk/Beagi argue as-applied challenge given Citizens United. | Beaumont controls; §441b(a) constitutionally bans direct corporate contributions as applied to all corporations. | No; §441b(a) constitutional as applied. |
| Does Beaumont govern post-Citizens United analysis? | Beaumont should be overruled or limited by Citizens United. | Beaumont remains good law and governs the direct-contribution ban for all corporations. | Beaumont governs; Citizens United did not overrule it. |
| Does the Agostini principle require applying older precedent despite later cases? | Agostini principle applied; lower courts should follow controlling, directly applicable precedents. |
Key Cases Cited
- Beaumont v. FEC, 539 U.S. 146 (Supreme Court, 2003) (upholds direct corporate-contribution ban; four government interests including anti-corruption and anti-circumvention)
- Citizens United v. FEC, 130 S. Ct. 876 (Supreme Court, 2010) (struck down corporate independent expenditures ban; did not overrule Beaumont on direct contributions)
- Agostini v. Felton, 521 U.S. 203 (Supreme Court, 1997) (establishes direct-application principle for controlling precedents)
- MCFL v. Benton?, 479 U.S. 288 (Supreme Court, 1986) (nonprofit corporations and First Amendment contribution/independent expenditures context)
- Buckley v. Valeo, 424 U.S. 1 (Supreme Court, 1976) (distinguishes scrutiny levels for independent expenditures vs contributions)