Court held that strict scrutiny should apply to both contributions and expenditure limitations.

Dissent rejects strict scrutiny of contribution and expenditure limits because these limits aren’t overbroad.

• Certain restrictions on contributions are far too great
• So drastic that they would impede someone running against an incumbent candidate

Main Idea

See rule.

Rule

Under the First Amendment,

1. No expenditure limits on political campaigns allowed unless it passes strict scrutiny; and
2. Contribution limits may be unconstitutional if they’re so low that they impede the state’s ability to accomplish their legitimate objectives.
3. Strict scrutiny should apply to both contributions and expenditure limitations.

Facts of the case

Campaign finance law (Act 64) imposed strict limits on both expenditures by currently-running candidates and contributions of individuals, political groups, and parties.

Neil Randall argued that Act 64’s low contribution limit violated his FA freedom of speech.

District Court:

“Vermont's interests in combating corruption and ensuring fair elections justifies all but one of the contribution limits, but none of the expenditure limits.”

• A contribution limit seems to have to be pretty low be unconstitutional.

Both parties appealed the ruling to the Second Circuit Court of Appeals, finding that the expenditure limits would be constitutional as long as they were "narrowly tailored" to the state's interests.

Question