RANDALL v. SORRELL

Legal Principle at Issue

Do expenditure limits for political candidates violate the First Amendment's guarantee of freedom of speech? And whether Vermont's contribution limits, which are the lowest in the country, fall below an acceptable constitutional threshold and should be struck down?

Action

Reversed and remanded. Petitioning party received a favorable disposition.

Facts/Syllabus

In this case, the Supreme Court considered the constitutionality of a Vermont campaign finance statute that limits both (1) the amounts that candidates for state office may spend on their campaigns (expenditure limitations) and (2) the amounts that individuals, organizations, and political parties may contribute to those campaigns (contribution limitations). Prior to 1997, Vermont’s campaign finance law imposed no limit upon the amount a candidate for state office could spend. It did, however, impose limits upon the amounts that individuals, corporations, and political committees could contribute to the campaign of such a candidate. Individuals and corporations could contribute no more than $1,000 to any candidate for state office. Political committees, excluding political parties, could contribute no more than $3,000. The statute imposed no limit on the amount that political parties could contribute to candidates.

In 1997, Vermont enacted a more stringent campaign finance law, Act 64, the statute at issue here. Act 64, which took effect immediately after the 1998 elections, imposes mandatory expenditure limits on the total amount a candidate for state office can spend during a “two-year general election cycle” (meaning the primary plus the general election) in approximately the following amounts: governor, $300,000; lieutenant governor, $100,000; other statewide offices, $45,000; state senator, $4,000 (plus an additional $2,500 for each additional seat in the district); state representative (two-member district), $3,000; and state representative (single member district), $2,000. §2805a(a). These limits are adjusted for inflation in odd-numbered years based on the Consumer Price Index. Incumbents seeking reelection to statewide office may spend no more than 85% of the above amounts, and incumbents seeking reelection to the state Senate or House may spend no more than 90% of the above amounts. Act 64 also imposes strict contribution limits. The amount any single individual can contribute to the campaign of a candidate for state office during a “two-year general election cycle” is limited as follows: governor, lieutenant governor, and other statewide offices, $400; state senator, $300; and state representative, $200. §2805(a). Unlike its expenditure limits, Act 64’s contribution limits are not indexed for inflation.

The petitioners are individuals who have run for state office in Vermont, citizens who vote in Vermont elections and contribute to Vermont campaigns, and political parties and committees that participate in Vermont politics. Soon after Act 64 became law, they brought this lawsuit in federal District Court against the respondents, state officials charged with enforcement of Act 64. The District Court agreed with the petitioners that Act 64's expenditure limits violate the First Amendment. The court also held unconstitutional the Act’s limits on the contributions of political parties to candidates. At the same time, the court found the Act’s other contribution limits constitutional.

Both sides appealed. A divided panel of the U.S. Court of Appeals for the Second Circuit in 2004 held that all of the Act’s contribution limits are constitutional. It also held that the Act’s expenditure limits may be constitutional. It found those limits supported by two compelling interests, namely, an interest in preventing corruption or the appearance of corruption and an interest in limiting the amount of time state officials must spend raising campaign funds. The Second Circuit then remanded the case to the District Court with instructions to determine whether the Act’s expenditure limits were narrowly tailored to those interests.