In Nixon v. Shrink (1/24/2000) a Missouri Governmental PAC and a candidate for the Republican nominee for state auditor sought to enjoin the enforcement of the state’s contribution limitation statue on the grounds that it violated their First and Fourteenth Amendment rights. The campaign contribution limits ranged from $250 to $1,000 depending on office and constituency size and was adjusted for inflation in even numbered years since January 1995.
Arguments and reference to Buckley v. Valeo were numerous. Buckley supported limiting individual contributions to any single candidate to $1,000. per election. Buckley, however, struck down the law that called for a $1,000 annual ceiling on independent expenditures linked to specific candidates. The Court found violations of the First Amendment in the expenditure regulations, but held the contribution restrictions constitutional.
The Court in reviewing Nixon found that “there is little reason to doubt that sometimes large contributions will work actual corruption of our political systems, and no reason to question the existence of a corresponding suspicion among voters.”
Continuing, the Court said: “Here, as in Buckley, ‘[t]here is no indication . . . that the contribution limitations imposed by the [law] would have any dramatic[ally] adverse effect on the funding of campaigns and political associations,’ and thus no showing that ‘the limitations prevented the candidates and political committees from amassing the resources necessary for effective advocacy.’ 424 U.S., at 21. The District Court found here that in the period since the Missouri limits became effective, ‘candidates for state elected office [have been] quite able to raise funds sufficient to run effective campaigns,’ 5 F. Supp. 2d, at 740, and that ‘candidates for political office in the state are still able to amass impressive campaign war chests.’”
Therefore, the Court found that the Buckley decision governs in the Nixon v. Shrink case. In other words, the contribution limitations in Missouri are constitutional. The Court also recognized that the perception that large money contributions receives a quid pro quo in our political system and that could undermine the integrity of and our political system itself. In the Court’s words, “Congress could legitimately conclude that the avoidance of the appearance of improper influence ‘is also critical … if confidence in the system of representative Government is not to be eroded to a disastrous extent.’”
For a syllabus, full version or edited decision of Nixon v. Shrink go to: