speechnow.org v. Federal Election Commission

Procedural entryThis page is a short order in speechnow.org v. Federal Election Commission. Read the opinion of the Court — 567 F. Supp. 2d 70
District Court, District of Columbia·Decided September 28, 2009·No. Civil Action No. 2008-0248·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SPEECHNOW.ORG, et al., : : Plaintiffs, : : v. : Civil Action No. 08-0248 (JR) : FEDERAL ELECTION COMMISSION, : : Defendant. :

MEMORANDUM AND FINDINGS

The plaintiffs filed a complaint and a motion for a

preliminary injunction in February 2008, asserting that it was

unconstitutional for the FEC to apply its contribution limit

rules to a group such as Speechnow. Speechnow’s business is so-

called “independent expenditures”: advertisements that advocate

the election or defeat of particular candidates, but are not

coordinated with any candidates or campaigns. Because these

advertisements have the purpose of promoting candidates, and

because Speechnow proposes to collect more that $1000 per year,

the FEC would regulate Speechnow as a political committee, and

place various limits on the contributions Speechnow could

receive.

In July 2008, I issued an order denying plaintiffs’

motion for a preliminary injunction. Dkt. 32. I found that the

contribution limits on independent expenditure groups supported a

substantial state interest, and that the plaintiffs were unlikely

to succeed on the merits. Plaintiffs appealed, but simultaneously pursued the unique procedure set forth in 2 U.S.C.

§ 437h, under which the constitutional questions presented would

be certified to the en banc Court of Appeals, following discovery

and findings of fact. After I agreed to certify five such

questions, plaintiffs held their appeal in abeyance.

The task before me is not to answer any constitutional

questions, or to render a judgment of any kind. Instead, I am to

make findings of fact that will allow the Court of Appeals to

answer the constitutional questions I certify.

The parties submitted several hundred proposed findings

of fact, accompanied by thousands of pages of studies, reports,

articles, and expert declarations. Most of the proposed

findings, and nearly all of the supporting material, centered on

the question of whether or not the challenged provisions are

necessary to ward off corruption -- or the appearance of

corruption -- in federal elections. To my mind, the facts needed

to answer that question are the kind of “facts” that legislatures

find. They are not the kind of facts that can be determined in a

judicial forum on the basis of a cold paper record full of

hearsay and opinion. Accordingly, I directed the parties jointly

to submit a set of proposed findings that focused on three

questions: (1) How is SpeechNow organized, and how are the

individual plaintiffs involved with it? (2) What are SpeechNow’s

plans? and (3) How do the challenged provisions affect

- 2 - SpeechNow’s plans? The findings provided below draw from that

document. They are essentially those findings on which the

parties agree, and are the kinds of facts (and conclusions of

law, see, e.g., ¶¶ 51-54) that are typically resolved in a

judicial forum.

Questions for Appeal

1. Whether the contribution limits contained in 2

U.S.C. §§ 441a(a)(1)(C) and 441a(a)(3) violate the First

Amendment by preventing David Keating, SpeechNow.org’s president

and treasurer, from accepting contributions to SpeechNow.org in

excess of the limits contained in §§ 441a(a)(1)(C) and

441a(a)(3).

2. Whether the contribution limit mandated by 2 U.S.C.

§ 441a(a)(1)(C) violates the First Amendment by preventing the

individual plaintiffs from making contributions to SpeechNow.org

in excess of $5000 per calendar year.

3. Whether the biennial aggregate contribution limit

mandated by 2 U.S.C. § 441a(a)(3) violates the First Amendment by

preventing Fred Young from making contributions to SpeechNow.org

that would exceed his individual biennial aggregate limit.

4. Whether the organizational, administrative, and

continuous reporting requirements set forth in 2 U.S.C. §§ 432,

433, and 434(a) violate the First Amendment by requiring David

Keating, SpeechNow.org’s president and treasurer, to register

- 3 - SpeechNow.org as a political committee, to adopt the

organizational structure of a political committee, and to comply

with the continuous reporting requirements that apply to

political committees.

5. Whether 2 U.S.C. §§ 431(4) and 431(8) violate the

First Amendment by requiring David Keating, SpeechNow.org’s

president and treasurer, to register SpeechNow.org as a political

committee and comply with the organizational and continuous

reporting requirements for political committees before

SpeechNow.org has made any expenditures or broadcast any

advertisements.

Findings of Fact

I. The structure of SpeechNow.org and the involvement of the individual plaintiffs

A. SpeechNow.org
1. SpeechNow.org (“SpeechNow”) is an unincorporated

nonprofit association organized under the District of Columbia

Uniform Unincorporated Nonprofit Associations Act, D.C. Code

§ 29- 971.01 et seq., and registered as a “political

organization” under section 527 of the Internal Revenue Code.

Keating Decl., Ex. G, SpeechNow.org Internal Revenue Form 8871.

2. The general powers of SpeechNow lie with five voting

“members”: David Keating, Jon Coupal, Edward Crane, Daniel

Shapiro, and Richard Marder. Bylaws, Art. I, § 5; Art. III,

§§ 1, 2.

- 4 - 3. SpeechNow’s bylaws designate four officers of the

association: president, vice president, secretary, and treasurer.

Id., Art. V, § 1. Keating is the president and treasurer of

SpeechNow, and he administers all of the association’s affairs.

Keating Decl. at ¶ 2. Coupal is the vice president and

secretary. Keating Decl., Ex. D, Member Action by Written

Consent in Lieu of an Organizational Meeting of SpeechNow.

4. SpeechNow undertakes that it will operate solely on

private donations from individuals. Keating Decl. at ¶ 8;

Bylaws, Art. II. Under its bylaws, SpeechNow cannot accept,

directly or indirectly, any donations or anything of value from

business corporations, labor organizations, national banks,

federal government contractors, foreign nationals, political

parties, or political committees. Keating Decl. at ¶ 8; Bylaws,

Art. VI, § 9; Art X, § 1.

5. Under its bylaws, SpeechNow cannot engage in

business activities, including the provision of any goods or

services, or any advertising or promotional activity that

resulting in income to SpeechNow, except as such activity may

attract membership dues or donations. Keating Decl. at ¶ 12.

SpeechNow cannot offer to any donors or members any benefit that

would operate as a disincentive for them to disassociate with

SpeechNow on the basis of the organization’s position on a

political issue, and it cannot offer its donors or members credit

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Related

Transferred
2 U.S.C. § 431(4)
Transferred
2 U.S.C. § 432
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2 U.S.C. § 433
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2 U.S.C. § 434(c)
Transferred
2 U.S.C. § 437g(d)
Transferred
2 U.S.C. § 437h
Transferred
2 U.S.C. § 441a(a)(1)(C)
Transferred
2 U.S.C. § 441d(d)(2)