Nixon v. Shrink Missouri Government Pac

528 U.S. 377 (2000)

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Nature of the Case

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Facts

A Missouri statute imposes contribution limits ranging from $250 to a $1,000, depending on specified state office or size of constituency. Respondents Shrink Missouri Government PAC, a political action committee, and Zev David Fredman, a candidate for the 1998 Republican nomination for state auditor, sought to enjoin enforcement of the contribution statute as violating their First and Fourteenth Amendment rights (presumably those of free speech, association, and equal protection, although the complaint did not so state). On cross-motions for summary judgment, the District Court sustained the statute. Applying Buckley v. Valeo, the court found adequate support for the law in the proposition that large contributions raise suspicions of influence peddling tending to undermine citizens' confidence 'in the integrity of . . . government.' The District Court rejected respondents' contention [528 U.S. 384] that inflation since Buckley's approval of a federal $1,000 restriction meant that the state limit of $1,075 for a statewide office could not be constitutional today. The Court of Appeals for the Eighth Circuit enjoined enforcement of the law pending appeal and reversed. Finding that Buckley had '`articulated and applied a strict scrutiny standard of review,'' the Court of Appeals held that Missouri was bound to demonstrate 'that it has a compelling interest and that the contribution limits at issue are narrowly drawn to serve that interest.' The appeals court treated Missouri's claim of a compelling interest 'in avoiding the corruption or the perception of corruption brought about when candidates for elective office accept large campaign contributions' as insufficient by itself to satisfy strict scrutiny.