Legal Library

Nixon v. Shrink Missouri Government PAC


On January 25, 1999, the U.S. Supreme Court announced that it had accepted Missouri's petition for review in Nixon v. Shrink Missouri Government PAC. This marked the first time since Buckley v. Valeo that the Court indicated it would address the constitutionality of campaign contribution limits. The issue before the Court in Shrink Missouri Government PAC was the constitutionality of Missouri's contribution limits for state office, which are $1,075 for statewide offices or any office covering a population of more than 250,000; $525 for state senator or other election districts with populations between 100,000 and 250,000; and $275 for state representative or any other office covering a population of less than 100,000.

The Institute served as counsel for amici secretaries of state in this important case. We filed an amicus brief in support of Missouri's petition for Supreme Court review and another amicus brief on the merits. In addition, the Institute provided expert advice to the Missouri Attorney General's office and to other amici counsel during the Supreme Court briefing.

The Supreme Court issued a ruling on January 24, 2000, upholding campaign contribution limits for Missouri's state elections. The ruling marks a major victory for the campaign finance reform movement. Click here to see our memorandum with key highlights of the Court's decision, along with our analysis.

The National Voting Rights Institute is proud to have helped defend Missouri's campaign contribution limits before the Supreme Court, serving as amicus counsel for a coalition of secretaries of state from across the country. We are also proud to have helped generate amici briefs from a coalition of state attorneys general (representing their respective states) and from a coalition of U.S. Senators and Members of Congress.

As described in our memorandum, the Nixon v. Shrink ruling represents a significant development in the movement to revisit the Court's 1976 ruling in Buckley v. Valeo striking down campaign spending limits on First Amendment grounds. Since our founding in 1994, the Institute has pushed for a reconsideration of Buckley, a position which four Supreme Court justices now appear willing to embrace. We have argued that Buckley should be revisited based on new facts and new interests, points which Justice Breyer raised in his concurrence and Justice Kennedy raised in his dissent. We have argued, alternatively, that Buckley's basic premise of money equaling speech should be revisited. Justice Stevens' concurrence is devoted to that point. Finally, Justice Breyer, in his concurrence, advances the equality argument, an argument which has served as the foundation of the Institute's work.