Herrmann v. Attorney General

CourtMassachusetts Supreme Judicial Court
DecidedMay 16, 2023
DocketSJC 13361
StatusPublished

This text of Herrmann v. Attorney General (Herrmann v. Attorney General) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Herrmann v. Attorney General, (Mass. 2023).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-13361

ROBERT HERRMANN & others1 vs. ATTORNEY GENERAL & another2 (and a consolidated case3).

Suffolk. February 6, 2023. - May 16, 2023.

Present: Budd, C.J., Gaziano, Lowy, Cypher, Kafker, Wendlandt, & Georges, JJ.

Initiative. Constitutional Law, Initiative petition, Political contributions. Elections, Political contributions. Political Committee. Moot Question. Attorney General.

Civil actions commenced in the Supreme Judicial Court for the county of Suffolk on October 24, 2022.

After consolidation, the cases were reported by Wendlandt, J.

Lawrence Lessig (Thomas O. Bean also present) for David C. Baxter & others. Ronald A. Fein (Courtney M. Hostetler & John C. Bonifaz also present) for Robert Herrmann & others. Anne Sterman, Assistant Attorney General (Adam Hornstine, Assistant Attorney General, also present) for the Attorney General & another.

1 Lars Mikkelsen, Joshua Redstone, and Graeme Sephton.

2 Secretary of the Commonwealth.

3 David C. Baxter & others vs. Attorney General & another. 2

Thaddeus A. Heuer, for Fiscal Alliance Foundation, amicus curiae, submitted a brief.

KAFKER, J. The plaintiffs seek review of the Attorney

General's decision not to certify their initiative petition.4

The plaintiffs' proposed law would have instituted limits on

contributions to independent expenditure political action

committees, more commonly known as "Super PACs." The Attorney

General determined that the proposed law conflicted with the

right of free speech protected by the Massachusetts Declaration

of Rights and that it therefore addressed an excluded subject

under art. 48 of the Amendments to the Massachusetts

Constitution, which sets out the procedures for the popular

initiative. See art. 48, The Initiative, II, § 2. In so

ruling, the Attorney General determined that United States

Supreme Court precedent precludes this type of limitation on

campaign contributions under the First Amendment to the United

States Constitution and that the State constitutional right of

free speech must extend at least as far as the cognate right

under the Federal Constitution. See 1A Auto, Inc. v. Director

4 The single justice consolidated two complaints from two separate groups of plaintiffs. Each plaintiff was one of the ten initial sponsors of the initiative petition. As explained infra, the two plaintiff groups seek identical relief but under different theories for why the proposed law is constitutional. 3

of the Office of Campaign & Political Fin., 480 Mass. 423, 440

(2018), cert. denied, 139 S. Ct. 2613 (2019).

After the plaintiffs brought these appeals challenging the

denial, the Attorney General offered to agree to a stipulated

order with the initiative proponents that would have allowed

them to gather the initial round of voter signatures required by

art. 48 during their appeals, despite the Attorney General's

conclusion that the initiative addressed an excluded subject.

See Abdow v. Attorney Gen., 468 Mass. 478, 485 (2014). The

proponents, however, refused to agree to such an order. The

Attorney General now contends that the appeals are moot, as the

proponents did not gather the first round of signatures by the

deadline required by art. 48.

We conclude that the cases are moot. When the petition was

filed in June 2022, the proponents initiated a streamlined

governmental process involving numerous State actors, including

the Attorney General, the Secretary of the Commonwealth, and the

General Court. The petitioners' filing with the Attorney

General was timely, as it was submitted "not later" than August

2022, as required by art. 48, The Initiative, II, § 3, as

amended by art. 74 of the Amendments. By filing at that

particular time, they established the particular assembling of

the General Court, and thus the legislative session, into which

they would have needed to introduce the petition: the 2023 4

session. It was not then within the control of the petitioners

to stop and restart the process, as they contend. They were

required to meet the subsequent deadlines. They did not,

however, meet the December 2022 deadline to file additional

signatures with the Secretary of the Commonwealth. Thus, the

cases are now moot.

Because the cases are moot and raise constitutional

questions, including Federal constitutional questions, we

decline to consider the merits. Lockhart v. Attorney Gen., 390

Mass. 780, 782 (1984). As a general matter, we avoid resolving

moot questions, unless they are important, likely to recur, and

otherwise avoid review. See Lynn v. Murrell, 489 Mass. 579, 583

(2022); Lockhart, supra at 783-784. Whether this issue is

likely to recur is a matter of speculation. At this point, only

the ten initial proponents have indicated their support for the

initiative. They gathered no additional signatures. Thus, it

is far from clear whether the proponents would, in a future

year, collect sufficient signatures to make the question a live

issue. The question, albeit important, is also one of

constitutional law. We are particularly reluctant to decide

constitutional questions in moot cases. See Murrell, supra at

584, quoting Lockhart, supra at 784. Finally, the issue

presented raises Federal as well as State constitutional issues,

requiring us to review and decide Federal constitutional 5

questions best left to the Federal judiciary. For all these

reasons, we decline to address the merits in these moot cases.5

Background. According to campaign finance law, political

action committees (PACs) that make expenditures that are

uncoordinated with political candidates are known as

"independent expenditure PACs" or "Super PACs." See G. L.

c. 55, § 18A (d). In June 2022, proponents of a law that would

limit individual contributions to independent expenditure PACs

submitted an initiative petition to the Attorney General. The

Attorney General declined to certify the petition in September

2022, as she determined that it was inconsistent with the right

of free speech protected by the Massachusetts Declaration of

Rights and thus addressed an excluded subject under art. 48.

She relied on Federal cases concluding that the First Amendment

precluded such limitations. In October 2022, the ten

proponents, split between two groups of plaintiffs, filed

complaints in the county court challenging the Attorney

General's decision not to certify the petition. The two groups

seek identical relief but have different theories for why the

proposed law is constitutional.

The Attorney General indicated to the plaintiffs that they

would need to submit additional signatures by December 2022, or

5 We acknowledge the amicus brief submitted by the Fiscal Alliance Foundation. 6

their appeals would become moot. To that end, she offered to

move for an order allowing the proponents to collect signatures

in advance of a judicial ruling on her denial, but the

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