McNeilly v. Land, No. 10-2244 (6th Cir. 2012)Annotate this Case
Plaintiff challenged the constitutionality of MCL 169.252(1), which sets limits on individual campaign contributions per “election cycle,” and includes criminal penalties. Plaintiff attested that he wished to make contributions to the candidate committees of individuals running for state House and state Senate in Michigan in 2010 in excess of the limits imposed for an individual. The district court denied a preliminary injunction to prevent enforcement. The Sixth Circuit affirmed. The district court properly considered that there was no showing of irreparable harm to plaintiff while there would be significant harm to defendant and the public if a preliminary injunction issued; that the only hard evidence in the case was that the statutory limits are not indexed to inflation, a showing that did not lead to the conclusion that plaintiff had a strong likelihood of success on the merits; and that there was no empirical evidence to determine the effect of individual contribution limits on the power to mount a campaign.