California Med. Assn. v. FEC
Annotate this Case
453 U.S. 182 (1981)
U.S. Supreme Court
California Med. Assn. v. FEC, 453 U.S. 182 (1981)
California Medical Association v. Federal Elections Commission
Argued January 19, 1981
Decided June 26, 1981
453 U.S. 182
One provision of the Federal Election Campaign Act of 1971 (Act), 2 U.S.C. § 441a(a)(1)(C), prohibits individuals and unincorporated associations from contributing more than $5,000 per calendar year to any multicandidate political committee. A related provision, § 441a(f), makes it unlawful for political committees knowingly to accept contributions exceeding the $5,000 limit. Appellant California Medical Association (CMA) is a not-for-profit unincorporated association of doctors, and appellant California Medical Political Action Committee (CALPAC) is a political committee formed by CMA and registered with appellee Federal Election Commission (FEC). When CMA and CALPAC were notified of an impending enforcement proceeding by the FEC for alleged violations of §§ 441a(a)(1)(C) and 441a(f), they, together with individual members, filed a declaratory judgment action in Federal District Court challenging the constitutionality of these provisions. Subsequently, the FEC filed its enforcement proceeding in the same District Court, and CMA and CALPAC pleaded as affirmative defenses the same constitutional claims raised in their declaratory judgment action. Pursuant to the special expedited review provisions of the Act, § 437h(a), the District Court, while the enforcement proceeding was still pending, certified the constitutional questions raised in the declaratory judgment action to the Court of Appeals, which rejected the constitutional claims and upheld the challenged $5,000 limit on annual contributions. Appellants sought review on direct appeal in this Court pursuant to § 437h(b).
641 F.2d 619, affirmed.
JUSTICE MARSHALL delivered the opinion of the Court with respect to Parts I, II, and IV, concluding that:
1. This Court has jurisdiction over the appeal. There is no merit to the FEC's contention that, in view of the overlapping provisions of the Act for judicial review of declaratory judgment actions, § 437h(a), and enforcement proceedings, § 437g(a)(10), and because Congress
failed to provide any mechanism for coordinating cases in which the same constitutional issues are raised by the same parties in both a declaratory judgment action and an enforcement proceeding, as here, a direct appeal to this Court under § 437h(b) should be limited to situations in which no enforcement proceedings are pending, since otherwise litigants, like appellants here, could disrupt and delay enforcement proceedings and undermine the functioning of the federal courts. Neither the statutory language nor legislative history of §§ 437g and 437h indicates that Congress intended such a limitation. Pp. 453 U. S. 187-192.
2. Section 441a(a)(1)(C) does not violate the equal protection component of the Fifth Amendment on the ground, alleged by appellants, that, because a corporation's or labor union's contributions to a segregated political fund are unlimited under the Act, an unincorporated association's contribution to a multicandidate political committee cannot be limited without violating equal protection. Appellants' contention ignores the fact that the Act as a whole imposes far fewer restrictions on individuals and unincorporated associations than it does on corporations and unions. The differing restrictions placed on individuals and unincorporated associations, on the one hand, and on corporations and unions, on the other, reflect a congressional judgment that these entities have differing structures and purposes and that they therefore may require different forms of regulation in order to protect the integrity of the political process. Pp. 453 U. S. 200-201.
JUSTICE MARSHALL, joined by JUSTICE BRENNAN, JUSTICE WHITE, and JUSTICE STEVENS, concluded in Part III that § 441a(a)(1)(C) does not violate the First Amendment. Nothing in § 441a(a)(1)(C) limits the amount CMA or any of its members may independently expend in order to advocate political views; rather, the provision restrains only the amount CMA may contribute to CALPAC. The "speech by proxy" that CMA seeks to achieve through its contributions to CALPAC is not the sort of political advocacy that this Court, in Buckley v. Valeo, 424 U. S. 1, found entitled to full First Amendment protection. Since CALPAC receives contributions from more than 50 persons a year, appellants' claim that CALPAC is merely the mouthpiece of CMA is untenable. CALPAC instead is a separate legal entity that receives funds from multiple sources and engages in independent political advocacy. If the First Amendment rights of a contributor are not infringed by limitations on the amount he may contribute to a campaign organization which advocates the views and candidacy of a particular candidate, Buckley v. Valeo, supra, the rights of a contributor are similarly not impaired by limits on the amount he may give to a multicandidate political committee, such as CALPAC, which advocates the
views and candidacies of a number of candidates. Moreover, the challenged contribution restriction, contrary to appellants' claim, is an appropriate means by which Congress could seek to protect the integrity of the contribution restrictions upheld in Buckley v. Valeo. Pp. 453 U. S. 193-199.
JUSTICE BLACKMUN concluded that the challenged contribution limitation does not violate the First Amendment because it is no broader than necessary to achieve the governmental interest in preventing actual or potential corruption. Pp. 453 U. S. 201-204.
MARSHALL, J., announced the Court's judgment and delivered the opinion of the Court with respect to Parts I, II, and IV, in which BRENNAN, WHITE, BLACKMUN, and STEVENS, JJ., joined, and an opinion with respect to Part III, in which BRENNAN, WHITE, and STEVENS, JJ., joined. BLACKMUN, J., filed an opinion concurring in part and concurring in the judgment, post, p. 453 U. S. 201. STEWART, J., filed a dissenting opinion, in which BURGER, C.J., and POWELL and REHNQUIST, JJ., joined, post, p. 453 U. S. 204.
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