Buckley v. Valeo
Buckley v. Valeo is a landmark Supreme Court case from 1976 that addressed the constitutionality of various provisions within the Federal Election Campaign Act. The ruling was complex and involved a divided court, with five justices dissenting in part. The Court struck down restrictions on how much individuals could contribute to their own campaigns, citing a violation of free speech, while upholding limitations on contributions from others directly to federal campaigns. Additionally, the decision deemed unconstitutional Congress's method of appointing a majority of the Federal Election Commission, asserting that this violated presidential appointment powers. The Court recognized the importance of public funding for campaigns, allowing limits on candidates who opted for such funding. They also established a system for federal income tax checkoff funds to support presidential candidates. The implications of Buckley v. Valeo continue to influence campaign finance laws and the regulation of political speech in the United States.
Buckley v. Valeo
Date: January 30, 1976
Citation: 424 U.S. 1
Issue: Campaign finance
Significance: The Supreme Court held that Congress cannot limit the amount of money candidates for political office contribute to their own campaigns, although the Court permitted other limits on campaign spending.
This complex, confusing, unsigned Supreme Court opinion was a decision rendered by shifting groups of five justices on the several sections of the case that voided parts of the 1971 Federal Election Campaign Act. Five out of eight justices actually dissented in part (Justice John Paul Stevens did not participate), so only three justices fully supported the decision. The Court struck down limits on how much individuals could contribute to their own campaigns as an improper infringement on free speech but upheld limits on what others could contribute directly to federal legislative campaigns. The Court also ruled unconstitutional Congress’s plan to appoint a majority of the Federal Election Commission, stating that it violated the clause that reserved appointment power for the president.
The Court approved public funding for campaigns but said that if a candidate accepted public funding, limits would be permissible. The Court allowed federal income tax checkoff funds for presidential primary candidates on a matching basis and for presidential general election candidates on a full-funding basis. In the 1985 case, Federal Election Commission v. the National Conservative Political Action Committee, the Court made it clear that limits could not be placed on those spending their own money independently to help a government-funded candidate.