Buckley v. Valeo
Citation and Court
424 U.S. 1 (1976) — Supreme Court of the United States
Facts
Following the Watergate scandal, Congress enacted the Federal Election Campaign Act (FECA), which imposed limits on campaign contributions, campaign expenditures, and independent expenditures, and established the Federal Election Commission (FEC). Senator James Buckley and others challenged FECA as violating the First Amendment and the Constitution’s Appointments Clause.
Issue
Whether FECA’s contribution limits, expenditure limits, independent expenditure limits, and the FEC’s composition are constitutional.
Holding
Contribution limits are constitutional (justified by preventing corruption and its appearance); direct campaign expenditure limits and independent expenditure limits are unconstitutional burdens on free speech. The FEC’s appointment structure violates the Appointments Clause because congressional leaders cannot appoint officers with executive functions.
Rule / Doctrine
Money as speech in campaign finance: political expenditures are a form of expression protected by the First Amendment. Contribution limits survive scrutiny because they prevent quid pro quo corruption while only marginally limiting expression; expenditure limits, however, impose direct and substantial restraints on political speech without equivalent justification. The Appointments Clause requires that officers of the United States be appointed by the President with Senate advice and consent, not by Congress.
Significance
Buckley v. Valeo is the foundational campaign finance case, establishing the doctrinal framework that has governed the field ever since. Its distinction between contributions (regulable) and expenditures (largely protected) underpins Citizens United v. FEC (2010) and the entire body of modern campaign finance law.