Buckley v. Valeo

Appellant
James L. Buckley
Appellee
Francis R. Valeo, Secretary of the U.S. Senate
Appellant's Claim
That various provisions of amendments to the Federal Election Campaign Act of1971 (FECA), regulating campaign contributions, violate the separation of powers doctrine, the First Amendment, and the Fifth Amendment.
Chief Lawyers for Appellant
Ralph K. Winter, Jr., Joel M. Gora, Brice M. Claggett
Chief Lawyers for Appellee
Daniel M. Friedman, Archibald Cox, Lloyd M. Cutler, Ralph S. Spritzer
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger, Thurgood Marshall, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart (unsigned)
Justices Dissenting
None (John Paul Stevens did not participate)
Place
Washington, D.C.
Date of Decision
30 January 1976
Decision
In a variety of different votes on different issues, the Supreme Court held:first, the doctrine of separation of powers prevents Congress from appointinga majority of the members of the Federal Election Commission (FEC), which administers FECA; second, while limits on contributions to political campaignsare constitutional, limits on campaign expenditures violate freedom of political expression protected by the First Amendment; and third, the FECA provisions authorizing public funding of political campaigns violate neither the First Amendment nor the Fifth Amendment's Due Process Clause, even though these provisions are more likely to help major parties and candidates than minor ones.
Significance
Buckley v. Valeo reshaped campaign finance laws entirely. Perhaps themost significant change, however, was the Court's ruling that there could beno restrictions on contributions from individuals and groups, so long as theywere independent of any official election campaigns. This ruling gave rise to a profusion of political action committees (PACs).
In 1974, Congress amended the Federal Election Campaign Act of 1971, and various candidates for political office, joined by some other politically activegroups and individuals, filed suit in the U.S. District Court for the District of Columbia in an attempt to prevent the amendments from affecting the 1976election. The suit raised a variety of complex constitutional questions, which both a three-judge panel from the district court and the U.S. Court of Appeals for the District of Columbia heard jointly. The constitutional attacks on FECA were rejected, so Buckley and the other appellants took their case tothe U.S. Supreme Court.
The Court's opinion was unsigned, and five of the justices dissented to various parts of it, but in various configurations, the participating members of the Court agreed on certain basic issues. To begin, the Court struck down a provision of the new law which permitted Congress to select a majority of the members of the Federal Election Commission, the body set up to administer theFECA. Since the Appointments Clause of Article I of the Constitution gave such power to the president, this provision was a violation of the doctrine of separation of powers, which prevents each of the three branches of the federalgovernment from assuming a responsibility that properly belongs to one of the other branches.
Court Distinguished Campaign Contributions from Expenditures
The appellants also challenged a provision of FECA that limited contributionsand expenditures in federal elections. The Court generally found contribution limits to be a proper legislative means of preventing candidates from becoming too reliant on large contributions. At the same time, however, the Courtupheld the right of "independent" individuals and groups to spend freely to help candidates, and ruled against limits on expenditures, which it found to be an impermissible violation of First Amendment guarantees of freedom of political expression.

The Act's contribution and expenditure limits operate in an area of the most fundamental First Amendment activities. Discussion of public issues and debate on the qualifications of candidates are integral to the operation of the system of government established by our Constitution. The First Amendment affords the broadest possible protection to such political expression in order "to assure [the] unfettered exchange of ideas for the bringing about of political and social changes desired by the people.

In addition to upholding the right of private citizens to spend money to helpelect the candidates of their choice--so long as these expenditures were notfunneled through the candidate or the candidate's campaign committee--the Court ruled in favor of an FECA provision authorizing new measures to promote public funding of presidential campaigns, such as the income tax check-off. While objections to this provision had cited both the First Amendment and the Fifth Amendment's Due Process Clause, the Court dismissed them. The provisionfurthered First Amendment values by using public moneys to encourage political debate. As to due process arguments contending that smaller parties and minor candidates would not benefit from this provision, the Court disagreed. TheCourt did, however, uphold the condition that any candidate accepting publiccampaign financing must agree to observe a ceiling on expenditures (althoughthis condition does not apply to those spending independently to elect a publicly funded candidate).
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