Dann v. Blackwell

83 F. Supp. 2d 906, 2000 U.S. Dist. LEXIS 1500, 2000 WL 194247
CourtDistrict Court, S.D. Ohio
DecidedFebruary 3, 2000
DocketC2-00-092
StatusPublished

This text of 83 F. Supp. 2d 906 (Dann v. Blackwell) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dann v. Blackwell, 83 F. Supp. 2d 906, 2000 U.S. Dist. LEXIS 1500, 2000 WL 194247 (S.D. Ohio 2000).

Opinion

OPINION AND ORDER

SARGUS, District Judge.

This matter is before the Court for consideration of Plaintiffs’ Motion for a Preliminary Injunction. Plaintiff, Marc E. Dann (“Dann”), is a candidate in the March 7, 2000 Democratic Party primary for the office of State Senate. Dann, together with Plaintiff, Marc Dann for Senate, his campaign committee, seeks to enjoin the Defendant, J. Kenneth Blackwell, the Ohio Secretary of State, 1 from enforcing Ohio Revised Code (“O.R.C.”) § 3517.103(C).

Plaintiffs bring a series of constitutional challenges to O.R.C. § 3517.103(C), the operation of which they contend prevents Dann from contributing more than $25,000 to his own campaign. Because the issues raised in the Motion for a Preliminary Injunction may substantially effect the conduct of both Dann and his four primary opponents in conducting their campaigns for public office, the Court considers these matters on an expedited basis. A hearing on the Motion was held on February 3, 2000. For the reasons that follow, Plaintiffs’ Motion for a Preliminary Injunction is GRANTED in part.

I.

In 1997, the Ohio General Assembly enacted Amended Substitute Senate Bill No. 116, which, inter alia, included two versions of O.R.C. § 3517.103, the constitutionality of which Plaintiffs now challenge. The legislation represented a major re *908 form of Ohio election law and included several prohibitions on campaign financing relevant to the issues before the Court.

Prior to the passage of Senate Bill 8 in 1995, Ohio law imposed no limits on the size of contributions made to political campaigns. The current Ohio law now limits the amounts that individuals, political parties, and political action committees may contribute to a candidate. 2 O.R.C. § 3517.102(B)(1) now provides:

No individual shall make a contribution or contributions aggregating more than:
(b) Two thousand five hundred dollars to the campaign committee of any one senate candidate in a primary election period or in a general election period.

The legislation imposed limitations on contributions, but did not otherwise restrict the amounts which a candidate could expend on a campaign for office. This distinction is not coincidental. It is clear that the Ohio legislature was aware that the same distinction has been drawn by the United States Supreme Court. As recently explained in Nixon v. Shrink Missouri Gov't PAC, — U.S. -, 120 S.Ct. 897, 145 L.Ed.2d 886 (2000):

While an expenditure limit “precludes most associations from effectively amplifying the voice of their adherents” ... the contributions limits “leave the contributor free to become a member of any political association and to assist personally in the association’s efforts on behalf of candidates ...” While we did not then say so in so many words that different standards might govern expenditure and contribution limits affecting associational rights, we have since then said so explicitly in Federal Election Comm’n v. Massachusetts Citizens for Life, Inc., 479 U.S. 238, 107 S.Ct. 616, 93 L.Ed.2d 539 (1986).

Id. at 903 (quoting Buckley v. Valeo, 424 U.S. 1, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976)).

In enacting Amended Substitute Senate Bill No. 116, it is-also clear that the Ohio General Assembly was mindful of the fact that in the seminal case of Buckley v. Valeo, 424 U.S. 1, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976), the Supreme Court struck down as unconstitutional federal legislation limiting the amounts of money the candidate could contribute to his or her own campaign. Amended Substitute Senate Bill No. 116 contains no limit on the amount which a candidate may contribute to the campaign.

The legislation does, however, require any candidate running for the State Senate or House to file what is termed a “personal funds notice” with the Ohio Secretary of State, if such candidate’s campaign committee has received or expects to receive personal funds in excess of $25,000.00 for either the primary or general election campaigns. 3 O.R.C. § 3517.103(C)(2). Personal funds include amounts contributed by the candidate, the candidates spouse, children, grandparents, and in-laws. O.R.C. § 3517.103.

If such personal funds notice is served by a candidate, an opposing candidate may in turn file a declaration that the campaign committee will accept contributions over and above the otherwise applicable limits on contributions from persons or entities other than the candidate. O.R.C. § 3517.103(D)(1). In essence, the legislative scheme provides that if one candidate contributes to the campaign personal funds in excess of $25,000, an opponent may opt *909 to be released from the $2,500 limit placed on campaign contributions. 4

Failure to timely file a personal funds notice carries severe consequences. Under O.R.C. § 3517.103(E)(4), a legislative candidate who fails to timely file such notice and contributes personal funds in excess of $25,000 “shall forfeit the candidate’s nomination, if the candidate was nominated, or the office to which the candidate was elected, if the candidate was elected to office.” 5

As originally enacted in 1997, O.R.C. § 3517.103(C)(3) required a personal funds notice to be filed not later than the earlier of the following two periods: (1) 120 days before the primary or general election; (2) two business days after the candidate’s campaign committee receives or expends personal funds in excess of $25,000. The same Act of the legislature passed in 1997 provided that the 120 day period would be in effect through December 31, 1999; thereafter, the Act provided that, effective January 1, 2000, the 120 day period would be shortened to 60 days. The version of O.R.C. § 3517.103

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Buckley v. Valeo
424 U.S. 1 (Supreme Court, 1976)
Elrod v. Burns
427 U.S. 347 (Supreme Court, 1976)
Pennhurst State School and Hospital v. Halderman
465 U.S. 89 (Supreme Court, 1984)
United States v. Salerno
481 U.S. 739 (Supreme Court, 1987)
Reno v. Flores
507 U.S. 292 (Supreme Court, 1993)
Nixon v. Shrink Missouri Government PAC
528 U.S. 377 (Supreme Court, 2000)
In Re Delorean Motor Company
755 F.2d 1223 (Sixth Circuit, 1985)
Frisch's Restaurant, Inc. v. Shoney's Inc.
759 F.2d 1261 (Sixth Circuit, 1985)
Gable v. Patton
142 F.3d 940 (Sixth Circuit, 1998)
Suster v. Marshall
149 F.3d 523 (Sixth Circuit, 1998)

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Bluebook (online)
83 F. Supp. 2d 906, 2000 U.S. Dist. LEXIS 1500, 2000 WL 194247, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dann-v-blackwell-ohsd-2000.