Minnesota Campaign-Finance Limit Enjoined
MINNEAPOLIS (CN) - A group of political candidates and campaign donors won an injunction against a limit in Minnesota on contributions individuals can make in a single election cycle.
U.S. District Court Judge Donovan Frank granted the injunction Monday, preventing the state from enforcing Minn. Statute 10A.27, subd. 11, which prevents individuals from contributing "an amount that is more than one-half the amount an individual may contribute during the election cycle segment."
In this case, the statute prevents individuals from donating more than $500 - half of the $1,000 single-donor limit - to state Legislature candidates, including plaintiffs Linda Runbeck, a state representative, and Scott Dutcher, who lost a 2012 election for state rep.
Runbeck and Dutcher claim they have been forced to return some donations to comply with the law. The remaining plaintiffs, donors Douglas Seaton and Van Carlson, say they have been unable to contribute their desired amounts, resulting in a chilling effect of their First Amendment rights.
Although he admitted that he does not necessarily agree with it, Judge Frank relied on the recent Supreme Court resolution of McCutcheon v. Federal Election Commission in shaping his decision and determining that the plaintiffs would likely succeed on their First Amendment claims.
Both cases deal with attempts to combat quid pro quo corruption through legislation and "level the playing field" for donors and candidates.
Judge Frank echoed the Supreme Court throughout his opinion, writing that "the government 'may not regulate contributions simply to reduce the amount of money in politics, or to restrict the political participation of some in order to enhance the relative influence of others.'"
"The McCutcheon court further held that 'the possibility that an individual who spends large sums may garner 'influence over or access to' elected officials or political parties' does not 'give rise to' quid pro quo corruption," Frank added. "Therefore, any statute aimed at combatting [sic] such influence or access - and not specifically targeted toward efforts 'to control the exercise of a [politician's] official duties' - is constitutionally prohibited."
Minnesota's statute effectively excludes donations of $1,000 by an individual based on the timing of the donations, a violation of free-speech rights, the court found.
"In Minnesota, the first twelve donors to a candidate for state house or senate may contribute the maximum of $1,000, but the thirteenth donor may contribute only $500 in order for the candidate not to exceed the special sources limit of $12,500," Frank wrote.
"In that manner, 'late' donations are arbitrarily treated differently than 'early' donations," he added. "One would assume that the thirteenth contribution to a legislative candidate in the amount of $1,000 causes no more concern of corruption than the first twelve $1,000 donations."
Judge Frank concluded with another swipe at McCutcheon by quoting Supreme Court Justice Stephen Breyer's dissent in that case.
"Instead of focusing on ... legitimate concerns, the McCutcheon decision 'understates the importance of protecting the political integrity of our governmental institutions' and 'creates a loophole that will allow a single individual to contribute millions of dollars to a political party or to a candidate's campaign,'" Frank wrote.
Ultimately, Frank conceded that he is bound by the Supreme Court's decision, and granted an injunction preventing the state from enforcing the statute inasmuch as it relates to individual "large contributors."