Buckley v. Valeo

The appellants also challenged a provision of FECA that limited contributions and 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 Court upheld 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 help elect the candidates of their choice--so long as these expenditures were not funneled 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 provision furthered 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. The Court did, however, uphold the condition that any candidate accepting public campaign financing must agree to observe a ceiling on expenditures (although this condition does not apply to those spending independently to elect a publicly funded candidate).