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Nixon v. Shrink Missouri Government PAC

The Brennan Center represented Missouri state Representative Joan Bray to defend the state’s contribution limits.

Published: January 24, 2000

Nixon v. Shrink Missouri Government PAC
Campaign Finance Reform

In 2000, the U.S. Supreme Court upheld Missouri’s law limiting contributions to statewide candidates to $1,075. A candidate and a political action committee had challenged the law, alleging that the limits it imposed on contributions to candidates for state office violated their First and Fourteenth Amendment rights. The case marked the first time since the 1976 landmark decision Buckley v. Valeo, which upheld $1,000 contribution caps, that the Court examined whether limiting individual contributions at approximately $1,000 is allowable under the First Amendment.

The Brennan Center, representing a defender of the contribution limit, Missouri state Representative Joan Bray, urged the Court to follow and uphold the Buckley decision. The Court accepted the arguments in the Center’s brief, finding that the fundamental principles established in Buckley applied on the state level as well. Additionally, the Court took an important step by removing doubt that the federal limits approved in Buckley also served to define the scope of permissible state limitations. Instead, according to the Court, no contribution limit is too low unless it is “so radical in effect as to render political association ineffective, drive the sound of a candidate’s voice below the level of notice, and render contributions pointless.”