Lair v. Motl, No. 16-35424 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit reversed the district court's judgment invalidating Montana's limits of the amount of money individuals, political action committees, and political parties may contribute to candidates for state elective office, Montana Code Annotated 13-37-216. The panel held that Montana has shown the risk of actual or perceived quid pro quo corruption in Montana politics was more than "mere conjecture," which was the low bar that it must overcome. The panel also held that Montana's limits were "closely drawn" to serve the state's anti-corruption interest, and the limits were tailored to avoid favoring incumbents, not to curtail the influence of political parties, and to permit candidates to raise enough money to make their voices heard.
Court Description: Civil Rights. The panel reversed the district court’s judgment in an action challenging Montana’s limits on the amount of money individuals, political action committees and political parties may contribute to candidates for state elective office. The panel held that Montana’s limits, as set forth in Montana Code Annotated § 13-37-216, were both justified by and adequately tailored to the state’s interest in combating quid pro quo corruption or its appearance. The panel held that Montana had shown the risk of actual or perceived quid pro quo corruption in Montana politics was more than “mere conjecture.” The state offered evidence of attempts to purchase legislative action with campaign contributions. The panel held that contribution limits served the state’s important interest in preventing this risk of corruption from becoming reality. The panel held that Montana’s limits were also “closely drawn” to serve the state’s anti-corruption interest. The limits targeted those contributions most likely to result in actual or perceived quid pro quo corruption – high-end, direct contributions with a significant impact on candidate fundraising. Moreover, the limits were tailored to avoid favoring incumbents, not to curtail the influence of political parties, and to permit candidates to raise enough money to make their voices heard. Although Montana’s limits were 4 LAIR V. MOTL lower than most other states’ in absolute terms, they were relatively high when comparing each state’s limits to the cost of campaigning there. Thus, Montana’s chosen limits fell within the realm of legislative judgments the courts could not second guess. Dissenting, Judge Bea stated that the district court properly evaluated the evidence submitted by Montana’s officials and found the officials had not established the only constitutionally permissible and valid state interest sufficient to justify Montana’s campaign contribution limits: the prevention of corruption or its appearance.
The court issued a subsequent related opinion or order on May 2, 2018.
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