California Medical Ass'n v. Federal Election Commission
1981 U.S. LEXIS 38, 101 S. Ct. 2712, 453 U.S. 182 (1981)
Rule of Law:
The Federal Election Campaign Act's limits on contributions by unincorporated associations to multicandidate political committees do not violate the First Amendment because they do not directly infringe political speech and serve the governmental interest in preventing corruption and its appearance, nor do they violate the Fifth Amendment's equal protection component given the overall regulatory scheme.
Facts:
- The California Medical Association (CMA) is a not-for-profit unincorporated association of approximately 25,000 doctors residing in California.
- In 1976, CMA formed the California Medical Political Action Committee (CALPAC), which registered as a multicandidate political committee.
- The Federal Election Campaign Act (FECA), specifically 2 U.S.C. § 441a(a)(1)(C), prohibits individuals and unincorporated associations like CMA from contributing more than $5,000 per calendar year to any multicandidate political committee, such as CALPAC.
- A related provision of the Act, 2 U.S.C. § 441a(f), makes it unlawful for political committees such as CALPAC to knowingly accept contributions exceeding this limit.
- CMA made annual contributions to CALPAC in excess of $5,000.
Procedural Posture:
- In October 1978, the Federal Election Commission (FEC) found 'reason to believe' that CMA had violated the Federal Election Campaign Act by making annual contributions to CALPAC in excess of $5,000, and that CALPAC had unlawfully accepted such contributions.
- After informal conciliation efforts failed, the FEC authorized its staff in April 1979 to institute a civil enforcement action against CMA and CALPAC in federal district court under 2 U.S.C. § 437g.
- In early May 1979, after receiving formal notification of the FEC’s impending enforcement action, CMA, CALPAC, and two individual members filed a declaratory judgment action in the United States District Court for the Northern District of California, challenging the constitutionality of the statutory contribution limitations under 2 U.S.C. § 437h.
- Several weeks later, the FEC filed its enforcement action against CMA and CALPAC in the same District Court, where CMA and CALPAC pleaded the same constitutional claims as affirmative defenses.
- On May 17, 1979, the District Court, pursuant to the special expedited review provisions of 2 U.S.C. § 437h, certified the constitutional questions raised in the declaratory judgment action to the Court of Appeals for the Ninth Circuit.
- In May 1980, a divided Court of Appeals for the Ninth Circuit, sitting en banc, rejected the appellants' (CMA and CALPAC) constitutional claims and upheld the $5,000 limit on annual contributions by unincorporated associations to multicandidate political committees.
- Appellants sought review of that determination in the Supreme Court, again pursuant to the special jurisdictional provisions of 2 U.S.C. § 437h.
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Issue:
Does the Federal Election Campaign Act's provision, 2 U.S.C. § 441a(a)(1)(C), limiting the amount an unincorporated association may contribute to a multicandidate political committee to $5,000 per calendar year, violate the First Amendment or the equal protection component of the Fifth Amendment?
Opinions:
Majority - Justice Marshall
Yes, the Federal Election Campaign Act's $5,000 annual limit on contributions by unincorporated associations to multicandidate political committees does not violate the First Amendment or the equal protection component of the Fifth Amendment. The Court first addressed jurisdiction, rejecting the Federal Election Commission's (FEC) argument that actions brought under § 437h (expedited review for constitutional questions) should be precluded when § 437g enforcement proceedings (regular enforcement) are contemplated or underway. The Court found no suggestion in the language or legislative history that Congress intended to limit § 437h in this manner, emphasizing the statute's requirement to "immediately . . . certify all questions of the constitutionality of this Act." Regarding the First Amendment, the Court reiterated the distinction made in Buckley v. Valeo between campaign expenditures, which directly restrain political speech and are highly protected, and campaign contributions, which involve a limited element of protected speech. The $5,000 annual limit on contributions to multicandidate political committees (CALPAC) does not restrict CMA's or its members' ability to engage in independent political advocacy or expend funds directly to express their political views. The Court characterized CMA’s contributions to CALPAC as “speech by proxy,” which is not entitled to the same level of First Amendment protection as direct political advocacy because CALPAC is a separate legal entity receiving funds from multiple sources. The Court further held that the contribution restriction serves the important governmental interest in preventing the actual or apparent corruption of the political process, a justification upheld in Buckley. This provision is an appropriate means to prevent the circumvention of other contribution limitations upheld in Buckley, such as the $1,000 limit on contributions to a candidate and the $25,000 aggregate annual limit on individual contributions. Without this limit, individuals or associations could channel unlimited funds through multicandidate political committees to candidates, thereby undermining the integrity of the electoral process. The Court also rejected the argument that contributions for administrative support should be unlimited, reasoning that such funds could allow a single donor to dominate a PAC’s operations and contribution policies. Regarding the Fifth Amendment's equal protection component, the Court found no discriminatory treatment of unincorporated associations compared to corporations and labor unions. While corporations and unions may establish segregated funds with unlimited contributions from their members, the Act as a whole imposes far fewer restrictions on individuals and unincorporated associations (e.g., unlimited independent expenditures) than on corporations and unions, which are generally barred from making direct political contributions. These differing restrictions reflect a congressional judgment that different entities require different forms of regulation to protect electoral integrity.
Dissenting - Justice Stewart
No, the Court should not have exercised jurisdiction over this appeal because a party formally notified of an impending § 437g enforcement proceeding should not be permitted to bring an action under § 437h raising precisely the same constitutional issues. Justice Stewart argued that allowing simultaneous proceedings under § 437g (enforcement) and § 437h (expedited constitutional review) interferes with the proper enforcement of the Federal Election Campaign Act and the sound functioning of the federal courts. He contended that although the Act’s language and legislative history do not directly address this specific overlap, the structure of the Act expresses Congress’s intent for these two provisions to serve distinct purposes with separate, tailored procedures. Congress carefully balanced public interest in expeditious resolution and respondent’s interest in fair procedures in § 437g, with specific timelines and limited appeal routes. Allowing a § 437g respondent to initiate a § 437h action disrupts this balance, causing delays and forcing federal appellate courts to hear cases en banc (a rare and burdensome procedure) and granting direct appeal to the Supreme Court—rights not otherwise available under § 437g. This dual litigation also strains the Federal Election Commission and can lead to piecemeal adjudication, where constitutional questions are decided prematurely without a fully developed factual record, or on broader grounds that might have been avoided in a § 437g proceeding. Justice Stewart concluded that the District Court should not have certified the case to the Court of Appeals, and therefore, the Court of Appeals lacked jurisdiction.
Concurring - Justice Blackmun
Yes, the $5,000 limitation on the amount that persons may contribute to multicandidate political committees is constitutional. Justice Blackmun joined Parts I, II, and IV of Justice Marshall's opinion (jurisdiction and equal protection). However, he wrote separately to express his view on the First Amendment claims (Part III). He disagreed with the plurality’s premise that contribution limitations are subject to a different, less rigorous First Amendment test than expenditure limitations. Instead, he maintained that both "implicate fundamental First Amendment interests" and governmental action curtailing associational freedoms should be subject to "closest scrutiny," requiring the State to demonstrate a "sufficiently important interest" and employ "means closely drawn to avoid unnecessary abridgment." Applying this rigorous standard, Justice Blackmun concurred in the judgment that the $5,000 limit is constitutional. He found that the important governmental interest in preventing actual or apparent political corruption, combined with the need to prevent evasion of the contribution limitations upheld in Buckley, justified the restriction. He emphasized that multicandidate political committees like CALPAC are "essentially conduits for contributions to candidates," and thus pose a perceived threat of corruption or its appearance. He stressed, however, that a different result would follow if the provision were applied to contributions to a political committee established solely for making independent expenditures, as such committees would not pose the same threat of corruption or circumvention of candidate contribution limits.
Analysis:
This case solidifies the distinction between political contributions and expenditures in First Amendment jurisprudence, reiterating Buckley v. Valeo's core holding that contribution limits are less restrictive of speech and are justifiable to prevent corruption or its appearance. It further extends this rationale to contributions made to multicandidate political committees, emphasizing their role as conduits for candidate contributions and the critical need to prevent circumvention of other valid limits. The ruling also clarifies the complex jurisdictional pathways under the Federal Election Campaign Act, allowing expedited constitutional challenges to proceed concurrently with enforcement actions, potentially leading to judicial inefficiencies but ensuring rapid review of statutory validity. This case reinforces Congress's broad power to regulate campaign finance to protect electoral integrity.
