Significance: With this ruling, the Supreme Court forced Congress to rework a piece of legislation in an unusually sweeping and substantial way. This case forced the Federal Election Commission (FEC) to rethink many of its policies on campaign contributions and spending.
Background: The Federal Election Campaign Act (FECA) of 1971 contained a provision allowing Congress to choose a majority of voting members on the FEC. Marguerite Buckley, representing the Los Angeles County Central Committee of the Peace and Freedom Party, sued Francis Valeo, the secretary of the U.S. Senate, objecting that this provision violated the appointments clause of the Constitution. This clause states that only the president can nominate officers to administrative agencies. FECA also placed limits on private campaign contributions and spending limits on candidates running for office.
Decision: This case was argued on November 10, 1975, and decided on January 30, 1976, by varying votes on specific questions. Chief Justice Warren Burger and Justices Harry Blackmun, William Rehnquist, Byron White, and Thurgood Marshall all dissented on various parts of the ruling; Justice John Paul Stevens did not participate. The opinion was unsigned. This ruling forced Congress to rewrite the part of the FECA that allowed it to choose the FEC’s voting members. The Court also ruled that the spending limits on candidates for office were unconstitutional violations of the First Amendment. The Court did, however, uphold the FEC’s limits on private contributions and its allowances for public funding of candidates’ campaigns.
Excerpt from the Opinion of the Court: “By contrast with a limitation upon expenditures for political expression, a limitation upon the amount that any one person or group may contribute to a candidate or political committee entails [involves] only a marginal [minor] restriction upon the contributor's ability to engage in free communication. A contribution serves as a general expression of support for the candidate and his views, but does not communicate the underlying basis for the support. . . . A limitation on the amount of money a person may give to a candidate or campaign organization thus involves little direct restraint on his political communication, for it permits the symbolic expression of support evidenced by a contribution but does not in any way infringe the contributor's freedom to discuss candidates and issues. . . .”
