[EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections

Smith, Brad BSmith at law.capital.edu
Tue Jul 19 13:54:04 PDT 2011


Yes
 
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp

________________________________

From: Rick Hasen [mailto:rhasen at law.uci.edu]
Sent: Tue 7/19/2011 4:51 PM
To: Smith, Brad
Subject: Re: [EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections


was this intended for the list?
came only to me

On 7/19/11 1:45 PM, Smith, Brad wrote: 

	You may be right. You do believe that aliens have First Amendment rights, don't you?
	 
	 
	Bradley A. Smith
	Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
	Capital University Law School
	303 E. Broad St.
	Columbus, OH 43215
	(614) 236-6317
	http://www.law.capital.edu/Faculty/Bios/bsmith.asp

________________________________

	From: Rick Hasen [mailto:rhasen at law.uci.edu]
	Sent: Tue 7/19/2011 2:50 PM
	To: Smith, Brad
	Cc: law-election at uci.edu
	Subject: Re: [EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections
	
	
	I wonder if others in the anti-regulation community share Brad's "no strong opinion" on this issue.  If the identity of the speaker doesn't matter, and more speech is always better, I'm not sure why foreign spending (though perhaps not foreign government spending?) would not also be celebrated along with corporate spending.
	
	
	
	On 7/19/2011 11:41 AM, Smith, Brad wrote: 

		I'm sorry my answer was unclear. I think FARA is constitutional. The question I don't care much about and have no strong opinion on is the one you ask. Either way that it would be decided would raise some knotty constitutional issues. But as Bill Mauer notes, presumably in this particular case, it's not an issue, for not only is this now a FARA case, but even if it were a conduit case I doubt the Government of Pakistan could claim a constitutional right.
		 
		Bradley A. Smith
		Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
		Capital University Law School
		303 E. Broad St.
		Columbus, OH 43215
		(614) 236-6317
		http://www.law.capital.edu/Faculty/Bios/bsmith.asp

________________________________

		From: law-election-bounces at department-lists.uci.edu on behalf of Rick Hasen
		Sent: Tue 7/19/2011 2:21 PM
		To: Smith, Brad
		Cc: law-election at uci.edu
		Subject: Re: [EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections
		
		
		I'm sorry that my question was unclear.  I'm not much interested in FARA either. I am asking whether 2 USC section 441e's bar on contributions and spending by foreign nationals would be unconstitutional as applied to foreign citizens, corporations, and governments (a) on U.S. soil and (b) not on U.S. soil.
		
		
		
		On 7/19/2011 11:12 AM, Smith, Brad wrote: 

			Does a foreign citizen on U.S. soil have First Amendment rights? Other constitutional rights? Could a foreign citizen on U.S. soil be prohibited from having an abortion (assuming Roe v. Wade remains the law)? From praying? From attending a campaign rally and cheering? From handing out flyers for a campaign? From performing a rock concert or making an appearance for a candidate? From endorsing a candidate?
			 
			I think FARA is constitutional. I don't really much care about this question either way, or have a strong opinion on it, but certainly the answer Rick obviously wants would raise lots of constitutional questions, too.
			 
			Bradley A. Smith
			Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
			Capital University Law School
			303 E. Broad St.
			Columbus, OH 43215
			(614) 236-6317
			http://www.law.capital.edu/Faculty/Bios/bsmith.asp

________________________________

			From: law-election-bounces at department-lists.uci.edu on behalf of Rick Hasen
			Sent: Tue 7/19/2011 1:20 PM
			To: Josiah Neeley
			Cc: 'law-election at uci.edu'
			Subject: Re: [EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections
			
			
			I believe it would apply if he were acting as a conduit for contributions from a foreign source.
			
			Assuming that's the case, would you or anyone else care to defend his constitutional right (or the rights of the Pakistani government or intelligence agency) to make contributions---or even independent expenditures---in federal electoins?
			
			
			
			On 7/19/2011 10:11 AM, Josiah Neeley wrote: 

				Here is a DoJ press release about the case. Mr. Kelner is correct that the prosecution is under FARA: 
				
				http://www.justice.gov/opa/pr/2011/July/11-nsd-937.html
				
				I would also add that Mr. Fai is a U.S. citizen, so a ban on contributions by foreign nationals would not apply to him. 
				
				________________________________________
				From: law-election-bounces at department-lists.uci.edu [law-election-bounces at department-lists.uci.edu] on behalf of Kelner, Robert [rkelner at cov.com]
				Sent: Tuesday, July 19, 2011 12:38 PM
				To: 'rhasen at law.uci.edu'; 'law-election at uci.edu'
				Subject: Re: [EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections
				
				Either way, there would be a violation of the Foreign Agents Registration Act, which is more likely the basis for the Government's investigation.
				
				From: Rick Hasen [mailto:rhasen at law.uci.edu]
				Sent: Tuesday, July 19, 2011 12:06 PM
				To: law-election at UCI.EDU <law-election at uci.edu> <mailto:law-election at uci.edu> 
				Subject: [EL] Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections
				
				Let's Put Citizens United to the Test: Pakistani Agent $ in U.S. Elections<http://electionlawblog.org/?p=20587> <http://electionlawblog.org/?p=20587> 
				Posted on July 19, 2011<http://electionlawblog.org/?p=20587> <http://electionlawblog.org/?p=20587>  by Rick Hasen<http://electionlawblog.org/?author=3> <http://electionlawblog.org/?author=3> 
				
				NBC's Pete Williams reports<http://firstread.msnbc.msn.com/_news/2011/07/19/7112067-fbi-arrests-pakistani-agent-for-making-political-contributions-in-us> <http://firstread.msnbc.msn.com/_news/2011/07/19/7112067-fbi-arrests-pakistani-agent-for-making-political-contributions-in-us>  "Law enforcement sources say the FBI has arrested an agent of Pakistan's official state intelligence service, accusing him of making thousands of dollars in political contributions in the United States without disclosing his connections to the Pakistani government."
				
				The conduct, if proven, is clearly illegal<http://us-code.vlex.com/vid/contributions-donations-foreign-nationals-19137877> <http://us-code.vlex.com/vid/contributions-donations-foreign-nationals-19137877>  under federal law.  But is that federal law unconstitutional?  Citizens United has told us that in the First Amendment independent spending context, the identity of the speaker does not matter for First Amendment purposes.  And further that independent spending cannot corrupt.  Some anti-campaign finance regulation folks have claimed that Citizens United should be extended to allow unlimited contributions, from whatever source, to candidates (and some even claim that it is unconstitutional to require even disclosure of such contributions).  That's Justice Thomas's position<http://ww
				 
				 
				
				 
				w.firstamendmentcenter.org/analysis.aspx?id=18
				 
				958> <http://www.firstamendmentcenter.org/analysis.aspx?id=18958>  too.
				
				So let's hear from these anti-regulatory folks.  If this activity is proven against the Pakistani agent, would prosecution of the agent be unconstitutional under the First Amendment?  (For my thoughts on the foreign national question, see my recent Michigan piece<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1620576> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1620576> .)
				
				[Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D20587&title=Let%E2%80%99s%20Put%20Citizens%20United%20to%20the%20Test%3A%20Pakistani%20Agent%20%24%20in%20U.S.%20Elections&description=Let%E2%80%99s%20Put%20Citizens%20United%20to%20the%20Test%3A%20Pakistani%20Agent%20%24%20in%20U.S.%20Elections%0D%0APosted%20on%20July%2019%2C%202011%20by%20Rick%20Hasen%0D%0A%0D%0ANBC%E2%80%99s%20Pete%20Williams%20reports%20%E2%80%9CLaw%20enforcement%20sources%20say%20the%20FBI%20has%20arrested%20an%20agent%20of%20Pakistan%E2%80%99s%20official%20state%20intelligence%20service%2C%20accusing%20him%20of%20making%20thousands%20of%20dollars%20in%20political%20contributions%20in%20the%20United%20States%20without%20disclosing%20his%20connections%20to%20the%20Pakistani%2
				 
				0government.%E2%80%9D%0D%0A%0D%0AThe%20conduct%2C%20if%20proven%2C%20is%20clearly%20illegal%20under%20federal%20law.%20%20But%20is%20that%20federal%20law%20unconstitutional%3F%20%20Citizens
				%20United%20has%20told%20us%20that%20in%20the%20First%20Amendment%20independent%20spending%20context%2C%20the%20identity%20of%20the%20speaker%20does%20not%20matter%20for%20First%20Amendment%20purposes.%20%20And%20further%20that%20independent%20spending%20cannot%20corrupt.%20%20Some%20anti-campaign%20finance%20regulation%20folks%20have%20claimed%20that%20Citizens%20United%20should%20be%20extended%20to%20allow%20unlimited%20contributions%2C%20from%20whatever%20source%2C%20to%20candidates%20%28and%20some%20even%20claim%20that%20it%20is%20unconstitutional%20to%20require%20even%20disclosure%20of%20such%20contributions%29.%20%20That%E2%80%99s%20Justice%20Thomas%E2%80%99s%20position%20too.%0D%0A%0D%0ASo%20let%E2%80%99s%20hear%20from%20these%20anti-regulatory%20folks.%20%20If%20this%20activity%20is%20proven%20against%20the%20Pakistani%20agent%2C%20would%20prosecution%20of%20the%20agent%20be%20unconstitutional%20under%20the%20First%20Amendment%3F%20%20%28For%20my%20thoughts%20on%20th
				 
				 
				
				 
				
				 
				e
				%20foreign%20national%20question%2C%20see%20my%20recent%20Michigan%20piece.%29%0D%0AShare%0D%0APosted%20in%20campaign%20finance%09%7C%20Comments%20Off>
				Posted in campaign finance<http://electionlawblog.org/?cat=10> <http://electionlawblog.org/?cat=10>  | Comments Off
				--
				Rick Hasen
				Professor of Law and Political Science
				UC Irvine School of Law
				401 E. Peltason Dr., Suite 1000
				Irvine, CA 92697-8000
				949.824.3072 - office
				949.824.0495 - fax
				rhasen at law.uci.edu<mailto:rhasen at law.uci.edu> <mailto:rhasen at law.uci.edu> 
				http://law.uci.edu/faculty/page1_r_hasen.html
				http://electionlawblog.org <http://electionlawblog.org/> 


			-- 
			Rick Hasen
			Professor of Law and Political Science
			UC Irvine School of Law
			401 E. Peltason Dr., Suite 1000
			Irvine, CA 92697-8000
			949.824.3072 - office
			949.824.0495 - fax
			rhasen at law.uci.edu
			http://law.uci.edu/faculty/page1_r_hasen.html
			http://electionlawblog.org <http://electionlawblog.org/> 
			


		-- 
		Rick Hasen
		Professor of Law and Political Science
		UC Irvine School of Law
		401 E. Peltason Dr., Suite 1000
		Irvine, CA 92697-8000
		949.824.3072 - office
		949.824.0495 - fax
		rhasen at law.uci.edu
		http://law.uci.edu/faculty/page1_r_hasen.html
		http://electionlawblog.org <http://electionlawblog.org/> 
		


	-- 
	Rick Hasen
	Professor of Law and Political Science
	UC Irvine School of Law
	401 E. Peltason Dr., Suite 1000
	Irvine, CA 92697-8000
	949.824.3072 - office
	949.824.0495 - fax
	rhasen at law.uci.edu
	http://law.uci.edu/faculty/page1_r_hasen.html
	http://electionlawblog.org <http://electionlawblog.org/> 
	


-- 
Rick Hasen
Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072 - office
949.824.0495 - fax
rhasen at law.uci.edu
http://law.uci.edu/faculty/page1_r_hasen.html
http://electionlawblog.org <http://electionlawblog.org/> 

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