Vermont passed a campaign
finance law (Act 64) that imposed
a very strict cap on making political contributions. The law also put a
cap on expenditures (how much money a candidate could spend).
Randall (who was running for
office) challenged the law as being an unconstitutional infringement of
the 1st Amendment's
right to free speech.
In Buckley v. Valeo (424 U.S. 1 (1976)), the US Supreme Court had
found that political contributions were a form of speech and thus covered
by the 1st Amendment.
The Trial Court found that Act
64's expenditure limits were
unconstitutional, but found the contribution limits to be constitutional.
Both Randall and Sorrell (Vermont's Attorney General) appealed.
Sorrell argued that the
expenditure limits were put in place to stop candidates from wasting time
Sorrell argued that Vermont
had a compelling government interest
in fighting corruption and ensuring fair elections.
The Appellate Court reversed
and found that both the contribution limits and the expenditure limits
were constitutional. Randall appealed.
The Appellate Court found
that expenditure limits could be constitutional as long as they were narrowly
The US Supreme Court reversed
and found both parts of Act 64 to
The US Supreme Court found
that expenditure limits violate the candidate's 1st
Amendment right to free speech.
The Court reaffirmed Buckley's prohibition on expenditure limits and found
that Vermont's compelling government interest in stopping
the candidates from wasting time raising money was not compelling enough
to be constitutional.
The Court found that
Vermont's contribution limits ($200-$400 per candidate) were too low, and
so were an infringement on the contributor's 1st Amendment right to free speech.
The Court acknowledged that
contribution limits could theoretically be constitutional, but not if
they were set so low as to be "disproportionate to the public
purposes they were enacted to advance."