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California Medical Association v. F.E.C.: 453 U.S. 182 (1981)

Published online by Cambridge University Press:  12 January 2018

Paweł Laider
Affiliation:
Jagiellonian University, Krakow
Maciej Turek
Affiliation:
Jagiellonian University, Krakow
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Summary

It seemed that after major changes in the original version of the Federal Election Campaign Act, which, among other reasons, resulted from a judicial review of the law by the Supreme Court, there would be no serious challenge to the constitutionality of campaign finance law. The analysis of the political and legal history of the 1980s and 1990s, however, reveals quite an opposite situation. In these two decades there were several suits in the federal courts, which raised various problems on the scope of the legislation, both from the procedural as well as substantive perspectives. One of the first important cases regarding the constitutionality of FECA was California Medical Association, et al. v. F.E.C., decided by the Supreme Court in 1981.

The petitioners, a non-profit medical organization, had created in the mid 1970s a political action committee (the California Medical Political Action Committee), the goal of which was to support candidates in legislative elections. As a formal committee, it was subject to the limitations imposed on similar organizations, stemming from the provisions of Federal Election Campaign Act. When the Federal Election Commission, responsible for overseeing the enforcement of federal campaign finance laws, found out that the committee had exceeded the acceptable contribution limits, it filed a lawsuit against the California Medical Association. After winning in the District Court, and losing in the Court of Appeals, the association brought the case to the Supreme Court. The issue was similar to the earlier challenges of the campaign finance laws, as it referred to the accordance of the Federal Election Campaign Act with the First Amendment's freedom of speech guarantees. The Court found that free speech was not violated by the contribution limits set by FECA, arguing that such limits served a compelling state interest: the protection of the integrity of the electoral process. The precedent was reached by a 5–4 margin, proving that the Justices were divided over the meaning of campaign finance restrictions, and the scope of the First Amendment's protection of candidates and other participants of the process.

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Publisher: Jagiellonian University Press
Print publication year: 2015

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