Buckley v. Valeo

Majority reasoning

The Court, in a per curiam opinion, reasoned that contribution limits impose only a marginal restriction on speech because they restrict the symbolic act of giving rather than the contributor's own communication, and that they serve a compelling interest in preventing corruption and its appearance without needing to be the least restrictive means available. By contrast, expenditure limits directly restrict the quantity of political expression itself, and the government's anti-corruption interest does not justify them because independent spending, uncoordinated with a candidate, poses little risk of a quid pro quo. The Court rejected the "equalizing relative influence" rationale for both types of limits, finding it "wholly foreign" to the First Amendment, which favors more speech, not less. On disclosure, the Court found the informational, anti-corruption, and enforcement interests substantial enough to survive strict scrutiny, though it required proof of a reasonable probability of harassment before minor parties could be exempted. On the FEC, the Court held that Congress cannot itself appoint officers who wield significant executive enforcement authority; such officers must be appointed under the Appointments Clause by the President, courts, or department heads, though the Commission's past actions and existing informational functions remain valid.

Dissent reasoning

Chief Justice Burger dissented in part, arguing that contributions and expenditures are "two sides of the same First Amendment coin" and that the Court's distinction between them is unprincipled; he would have struck down contribution limits, the $10/$100 disclosure thresholds as irrationally low relics of a 1910 statute, and the entire public financing scheme as an improper government intrusion into private political activity that also discriminates against minor parties. Justice White dissented in part, arguing the Court should have upheld the expenditure limits too, since Congress reasonably concluded they were necessary to prevent circumvention of contribution limits, reduce corruption, and ease candidates' fundraising burdens; he found the majority's distinction between "authorized" and "independent" spending artificial and easily evaded. Justice Marshall dissented in part, arguing that the limit on candidates spending their own personal wealth should have been upheld because, combined with contribution limits, it prevents wealthy candidates from having an insurmountable advantage and promotes equal access to the political arena. Justice Blackmun dissented in part, stating he saw no principled constitutional distinction between contribution and expenditure limits and would have applied the same analysis to both. Justice Rehnquist dissented in part, arguing that the public financing scheme's preferential treatment of major parties over minor parties and independents was not adequately justified and violated the First and Fifth Amendments by entrenching the two-party system.