[EL] big 2d Circuit campaign finance case; more news

Rick Hasen rhasen at law.uci.edu
Wed Jul 2 11:16:57 PDT 2014


A reader points out that in my post below I incorrectly called Carey v 
FEC a DC Circuit case. It was a trial court case.
Sorry for the error.

On 7/2/14, 9:27 AM, Rick Hasen wrote:
>
>
>     Big Campaign Finance News: Second Circuit Accepts Limits on
>     Contributions to Independent Campaign Committees in Some
>     Circumstances, Creating Circuit Split
>     <http://electionlawblog.org/?p=62960>
>
> Posted on July 2, 2014 9:26 am <http://electionlawblog.org/?p=62960>by 
> Rick Hasen <http://electionlawblog.org/?author=3>
>
> Today a unanimous Second Circuit panel issued an 84-page opinion in 
> Vermont Right to Life, Inc. v. Sorrell 
> <http://electionlawblog.org/wp-content/uploads/12-2904_opn.pdf>. Most 
> of the opinion is devoted tor rejecting a number of arguments raised 
> against Vermont disclosure rules applied to independent groups. This 
> is quite consistent with the rulings of other courts since /Citizens 
> United//: /most disclosure challenges have failed.
>
> But the most interesting part of the decision comes in the last 22 
> pages or so. As I understand it, Vermont Right to Life had two 
> committees, one which made only independent expenditures (what we 
> would now generally call a Super PAC) and another which made 
> contributions to candidates. The Second Circuit agreed that if there 
> were just the Super PAC, it would be unconstitutional to limit 
> contributions to the group (following the Citizens United-SpeechNow 
> line of cases).  But VRTL did not dispute that the two different 
> groups were "enmeshed" with one another, and the Second Circuit held 
> that the overlap between the two groups provided a basis for limiting 
> contributions to /both/ of them. A separate bank account is not enough 
> according to the Second Circuit, although it seems to be enough in 
> other circuits (see, e.g., the Carey v. FEC case from the D.C. 
> Circuit).  This sets up a Circuit split and the potential for either 
> en banc review in the Second Circuit or Supreme Court review.
>
> Here is the relevant language about enmeshment beginning on page 68:
>
>     Although some courts have held that the creation of separate bank
>     accounts is by itself sufficient to treat the entity as an
>     independent-expenditure-only group, see, e.g.,Emily's List v. Fed.
>     Election Comm'n, 581 F.3d 1, 12 (D.C. Cir. 2009),21 we do not
>     believe that is 1 enough to ensure there is a lack of
>     ""prearrangement and coordination." A separate bank account may be
>     relevant, but it does not prevent coordinated expenditures --
>     whereby funds are spent in coordination with the candidate. See
>     Stop This Insanity, Inc. Emp. Leadership Fund v. Fed. Election
>     Comm'n, 902 F. Supp. 2d 23, 43 (D.D.C. 2012). Nor is it enough to
>     merely state in organizational documents that a group is an
>     independent-expenditure-only group. Some actual organizational
>     separation between the groups must exist to assure that the
>     expenditures are in fact uncoordinated. We therefore decline to
>     adopt the reasoning of the Fourth Circuit in NCRL III. There, the
>     Fourth Circuit rejected North Carolina's argument that NCRL-FIPE
>     (a similar organization to VRLC-FIPE) was "not actually an
>     independent expenditure committee because it [was] 'closely
>     intertwined'" with NCRL and NCRL-PAC, two organizations (similar
>     to VRLC and VRLC-PC) that did not limit their activities to
>     independent expenditures. NCRL III, 525 F.3d at 294 n.8. The
>     Fourth Circuit concluded based only on NCRL-FIPE's organizational
>     documents that the group was "independent as a matter of law."22
>     Id. We do not agree that organizational documents alone satisfy
>     the anti-corruption concern with coordinated expenditures that may
>     justify contribution limits.
>
>     There is little guidance from other courts on examining
>     coordination of expenditures, but we conclude that, at a minimum,
>     there must be some organizational separation to lessen the risks
>     of coordinated expenditures. Separate bank accounts and
>     organizational documents do not ensure that "information [] will
>     only be used for independent expenditures." Catholic Leadership
>     Coal. of Tex. v. Reisman, No. A-12-CA-566-SS, 2013 WL 2404066, at
>     *177 (W.D. Tex. May 30, 2013) (emphasis added) ("The informational
>     wall [that plaintiff] asserts it can raise to keep its independent
>     expenditure activities entirely separate from its direct campaign
>     contribution activities is thin at best. This triggers the precise
>     dangers of corruption, and the appearance of corruption, which
>     motivated the Court in Buckley to uphold the challenged
>     contribution limits."). As discussed below, whether a group is
>     functionally distinct from a non-independent-expenditure-only
>     entity may depend on factors such as the overlap of staff and
>     resources, the lack of financial independence, the coordination of
>     activities, and the flow of information between the entities.
>
> Share 
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D62960&title=Big%20Campaign%20Finance%20News%3A%20Second%20Circuit%20Accepts%20Limits%20on%20Contributions%20to%20Independent%20Campaign%20Committees%20in%20Some%20Circumstances%2C%20Creating%20Circuit%20Split&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>
>
>
>     "Why the Civil Rights Act Couldn't Pass Today"
>     <http://electionlawblog.org/?p=62957>
>
> Posted on July 2, 2014 8:38 am <http://electionlawblog.org/?p=62957>by 
> Rick Hasen <http://electionlawblog.org/?author=3>
>
> Todd Purdum, author of the new book, An Idea Whose Time Has Come: Two 
> Presidents, Two Parties and the Battle for the Civil Rights Act of 
> 1964 <http://us.macmillan.com/anideawhosetimehascome/ToddPurdum>, has 
> writtenthis article in 
> <http://dyn.politico.com/printstory.cfm?uuid=4C8AD4D6-4E72-4C84-B19E-67B19252CE4C> 
> Politico, which also discusses the Voting Rights Act renewal.
>
> Share 
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D62957&title=%E2%80%9CWhy%20the%20Civil%20Rights%20Act%20Couldn%E2%80%99t%20Pass%20Today%E2%80%9D&description=>
> Posted in Voting Rights Act <http://electionlawblog.org/?cat=15>
>
>
>     "The Defiant Mississippi Loser" <http://electionlawblog.org/?p=62955>
>
> Posted on July 2, 2014 8:34 am <http://electionlawblog.org/?p=62955>by 
> Rick Hasen <http://electionlawblog.org/?author=3>
>
> /The Hill/ reports 
> <http://thehill.com/blogs/ballot-box/senate-races/211127-the-defiant-mississippi-loser>on 
> McDaniel's efforts to challenge the #MSSEN results.
>
> Share 
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D62955&title=%E2%80%9CThe%20Defiant%20Mississippi%20Loser%E2%80%9D&description=>
> Posted in campaigns <http://electionlawblog.org/?cat=59>, recounts 
> <http://electionlawblog.org/?cat=50>
>
>
>     "Marijuana, Voters Bill of Rights to miss Nov. ballot"
>     <http://electionlawblog.org/?p=62953>
>
> Posted on July 2, 2014 8:33 am <http://electionlawblog.org/?p=62953>by 
> Rick Hasen <http://electionlawblog.org/?author=3>
>
> The latest 
> <http://www.cincinnati.com/story/news/politics/elections/2014/07/01/marijuana-voters-bill-of-rights-to-miss-november-ballot/11901311/> 
> from Ohio.
>
> Share 
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D62953&title=%E2%80%9CMarijuana%2C%20Voters%20Bill%20of%20Rights%20to%20miss%20Nov.%20ballot%E2%80%9D&description=>
> Posted in The Voting Wars <http://electionlawblog.org/?cat=60>
>
>
>
> -- 
> Rick Hasen
> Chancellor's 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://www.law.uci.edu/faculty/full-time/hasen/
> http://electionlawblog.org
>
>
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-- 
Rick Hasen
Chancellor's 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://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org

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