Missourians for Fiscal Accountability v. Klahr, No. 17-1314 (8th Cir. 2018)
Annotate this CaseUnder Missouri campaign finance law, chapter 130, a “campaign committee” is formed to receive contributions or make expenditures solely to support or oppose particular ballot measures, "such committee shall be formed no later than thirty days prior to the election for which the committee receives contributions or makes expenditures." Thirteen days before the November 2014 general election, a group formed MFA as a campaign committee, to accept contributions and make expenditures in support of Proposition 10. MFA sued to enjoin enforcement of the formation deadline, citing the First Amendment. The district court granted MFA a temporary restraining order. MFA received contributions and made expenditures before the election. After the election, MFA terminated as a campaign committee. The Eighth Circuit affirmed summary judgment in favor of MFA. While a formation deadline by itself might not expressly limit speech, the deadline here is more than a disclosure requirement because it prohibits (or significantly burdens) formation of a campaign committee, a requisite for legally engaging in speech, even if the individual or group is willing to comply with organizational and disclosure requirements. Even if the state’s interest in preventing circumvention of chapter 130’s disclosure regime is compelling, the formation deadline is unconstitutional because it is not narrowly tailored, given its burden on speech and its modest effect on preventing circumvention of the disclosure regime.
Court Description: Benton, Author, with Loken and Erickson, Circuit Judges] Civil case - Campaign Finance Law. For the court's prior opinion in this matter, see Missourians for Fiscal Accountability v. Klahr, 830 F.3d 789 (8th Cir. 2016). In action seeking to declare unconstitutional and enjoin enforcement of Missouri's 30-day formation deadline for campaign committees, the district court did not err in enjoining enforcement of Section 130.011(8)RSMO Supp. 2013; assuming, without deciding that the rationale behind the statute is compelling, the formation deadline is unconstitutional because it is not narrowly tailored.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.