HIGH COURT MANDATES EQUAL CONTRIBUTION LIMITS

RARE VICTORY FOR EQUAL TREATMENT FOR ALL CANDIDATES

On June 26, the U.S. Supreme Court ruled in Davis v Federal Election Commission that the Constitution does not permit the government to set different contribution limits for candidates for the same office. Specifically, it is unconstitutional to mandate that candidates who spend $350,000 of their own funds on their own campaign face a contribution limit of $2,300, while their opponents face a contribution limit of $6,900.

This is the third time that the Supreme Court has ruled that the Constitution forbids the government from treating candidates unequally. The first such decision was Anderson v Celebrezze, which said that the government cannot force groups outside the major parties to select their presidential candidates before the major parties select their candidates.

The second such decision was Cook v Gralike. It said the government cannot put disparaging labels on the ballot for some candidates, while omitting such labels for other candidates. It says that the government may not "favor or disfavor a class of candidates".

The third such decision, Davis v FEC, was triggered by the McCain-Feingold Campaign Finance Law, passed in 2002. Included in that law was a provision called the "Millionaire’s Amendment." Normally, an individual can only contribute $2,300 to a candidate for federal office. The Amendment said that if a candidate either gives himself or herself $350,000 in personal funds, then all the opponents of that candidate can receive $6,900, triple the normal amount. The Amendment also said that the favored candidates could receive unlimited donations from that candidate’s own political party. Normally, a political party can only give $42,000 to its own U.S. House candidates.

Davis v FEC says, "The Constitution confers upon voters, not Congress, the power to choose the Members of the House of Representatives, Art. I, sec. 2, and it is a dangerous business for Congress to use the election laws to influence the voters’ choices." The decision was written by Justice Samuel Alito, and was co-signed by Chief Justice John Roberts and Justices Anthony Kennedy, Antonin Scalia, and Clarence Thomas. The other four Justices voted to uphold the "Millionaire’s Amendment."

The Supreme Court has failed to mandate equal treatment for candidates on several occasions in the past. In Arkansas Educational Television Commission v Forbes, 523 U.S. 666 (1998), it said that government TV stations may host candidate debates and pick and choose which ballot-listed candidates to invite. In Jenness v Fortson, it said that government may require some candidates to obtain very difficult petitions while permitting others to run for office with no petition whatsoever. In Buckley v Valeo, it said the government may give general election public funding (in advance of any particular presidential election) to old parties, but not to new parties.

Davis v FEC was filed by Jack Davis, the Democratic Party nominee in 2004 and 2006 from New York’s 26^th district. The district is reliably Republican, taking in rural and suburban voters who live between Buffalo and Rochester. The incumbent, since 1998, has been Tom Reynolds. He has been chair of the National Republican Campaign Committee. Reynolds spent approximately $5,000,000 in his 2006 re-election campaign; Davis spent $2,000,000. Yet the FEC fined Davis $251,000 for spending more than $350,000 of his own money and failing to reveal this in a timely manner.

Now that Davis has won the case, he is not obliged to pay the fine. The FEC had agreed to postpone collection of the fine until after the Court case was settled.

Davis’s brief makes the point that some candidates for Congress have neither personal wealth, nor the support of large political parties, nor a network of donors who are capable of making thousand-dollar donations. If Congress had really been interested in seeing to it that all candidates for Congress have equal or substantial financial resources, Congress could have passed public funding for Congressional candidates. But it has not done so.

Davis was assisted by a very effective amicus curiae brief filed by two other Congressional candidates who had been fined for violating the "Millionaire’s Amendment", even though neither was a millionaire. One of them, Oscar DeRossett, lost the Republican primary in Michigan’s 7^th district in 2004, even though he had mortgaged his home and raided his retirement savings. Since he had spent $530,000 of his own money, and had not informed his opponents of this fact within 24 hours, the FEC fined him $59,000. Since the law went into effect in 2004, six additional congressional candidates had also been fined for spending over $350,000 of their own money and not reporting it quickly.

The "Millionaire’s Amendment" does not apply to presidential candidates. If it had, all the Democrats running for the Democratic presidential nomination this year would have been able to receive campaign contributions of $6,900 from individuals, except that Hillary Clinton would have been limited to $2,300 contributions. This is because Clinton spent more than $350,000 of her own funds on her own campaign.

On June 2, U.S. District Court Judge Gregory L. Frost issued an injunction against an Ohio election law that restricts who can circulate independent candidate petitions. The injunction says the law, barring out-of-staters from circulating an independent candidate petition, is probably unconstitutional. While the case is pending, the law cannot be enforced. Moore v Brunner, 2:08cv-224. On June 6, Ohio officials said they would not appeal the injunction.

Ohio does not actually have a law that bars out-of-state circulators for independent candidates. Instead, it has an even more restrictive law that says circulators for an independent candidate must be registered voters. That is obviously unconstitutional, because in 1999 the U.S. Supreme Court ruled in Buckley v American Constitutional Law Foundation that states cannot require circulators to be registered voters. Ohio tried to persuade Judge Frost to interpret the Ohio law so that Ohio residents could circulate for an independent but that out-of-staters couldn’t. But the Judge didn’t do that, which would have required him to, in a sense, re-write the law.

The case had been brought by Brian Moore, presidential nominee of the Socialist Party. This is the first constitutional election lawsuit that the Socialist Party has filed in over ten years. The Ohio restriction on who can circulate for an independent candidate is particularly silly, since Ohio lets any adult (regardless of residence) circulate a petition for a new or previously unqualified political party.

On June 19, the Rhode Island legislature passed S 2112, the National Popular Vote Plan. If the Governor signs it, that will make five states that have passed the plan. The Governor has ten days to decide whether to sign or veto it, but the ten days don’t start until he receives the bill, and the legislature still hasn’t sent it over.

Florida: on June 11, proponents of an initiative filed a lawsuit against the deadline for initiative petitions. In 2007 the legislature moved the deadline for an initiative petition from July of the election year, to December of the year before the election. The lawsuit challenges the deadline, and also complains that each county has its own standards for rejecting signatures. Fla. Hometown Democracy v Browning, 08-80636, Miami. The initiative has gathered hundreds of thousands of signatures, and would require votes when a local government adopts a new land use plan.

Florida (2): on June 16, a state court ruled against ballot access for two major party members, who were seeking to get on the primary ballot for U.S. House. The candidates filed the wrong declaration of candidacy forms. The law says the Secretary of State shall furnish the proper forms. But the Court ruled that since the Secretary of State has all the forms on the Internet, that satisfies the state’s duty. The candidates were not incumbents. They were Larry Byrnes in the 14^th district, a Democrat, and Bob Hering in the 8^th district, a Republican.

Georgia: Faye Coffield has been trying to get on the ballot as an independent candidate for U.S. House, 4^th district. She needs either 15,061 valid signatures, or 14,887 (the state has contradicted itself; the formula is 5% of the number of registered voters as of October 2006). The deadline is July 8. She has collected 2,200 and has no chance of meeting the requirement, but she expects to file a lawsuit against the petition requirement. Because no independent has met the 5% petition requirement for U.S. House in Georgia since 1964, and because the U.S. Supreme Court has said that ballot access laws should be judged by how often they are used, her lawsuit could be potent. Although the Libertarian Party in the past has also sued to overturn the 5% requirement for U.S. House candidates, its plaintiff-candidates had not actually tried to qualify, so the Coffield lawsuit will be stronger.

Georgia (2): on May 23, the Georgia Democratic Party filed a lawsuit against the law that requires voters at the polls to show government-photo ID. The lawsuit charges the law violates the State Constitution. Democratic Party of Georgia v Perdue, Fulton Co., 2008-cv-151081.

Hawaii: on May 30, Ralph Nader filed a notice of appeal to the 9^th circuit in his 2004 ballot access case. The issues are whether a state can require six times as many signatures for an independent presidential candidate as for a new party, and also whether the state’s petition-checking procedures violate due process.

Idaho: the state Republican Party is going ahead with its lawsuit for a closed primary for itself, even though the recent state convention added an anti-closed primary plank to the state platform (the plank passed by only four votes). The plank is not in effect until the state committee of the party considers it, in the fall.

Indiana: on June 20, the League of Women Voters filed a lawsuit in state court against the law requiring voters to show government photo-ID in order to vote at the polls. League of Women Voters v Rokita. The lawsuit depends on the State Constitution.

Massachusetts: the Libertarian Party is about to sue, over the state’s refusal to let the party substitute its actual presidential candidate, Bob Barr, for the stand-in, George Phillies. The Massachusetts ACLU has agreed to represent the party. Massachusetts permitted vice-presidential substitution in 1980 for John Anderson, and ruled in 1995 that substitution is also permitted for president. In 2000, though, the state ruled that the stand-in must be a bona fide candidate who is sincerely seeking the nomination. Because of the 2000 ruling, the Massachusetts Libertarian petition listed George Phillies, who met that description. Now the state has said it won’t permit substitution, even though as recently as 2004 it told Ralph Nader that it would permit him to substitute his actual vice-presidential candidate for his stand-in.

Mississippi: the Democratic Party won’t file a new lawsuit to obtain a closed primary for itself. It had earlier lost its first lawsuit, on procedural grounds.

New Hampshire: the Libertarian Party will probably soon file a lawsuit over presidential substitution, similar to the Massachusetts lawsuit. New Hampshire has never permitted presidential substitution; and vice-presidential substitution has never been an issue in New Hampshire, because the petition does not list the vice-presidential nominee. The Libertarian Party avoided substitution problems in New Hampshire in 1996 because it was a qualified party at the time, and it avoided the problem in 2000 because it did the full party petition. In 2004 it failed to get on the ballot for president. As a backup strategy, the party is also circulating a new petition listing Bob Barr. If the proposed lawsuit fails, and the Barr petition succeeds, the state will list two Libertarians on the ballot for president, both with the same label.

New York: on June 10, the highest state court ruled that state parties may take control away from local units of the party and centralize it in the hands of the state party officers. Specifically, state parties may control which non-members of the party are permitted to run in the party’s primaries. There were two lawsuits, one involving the Working Families Party (Master v Pohanka), and one for the Independence Party (Conroy v State Committee of Independence Party).

North Carolina: on June 10, the Green and Libertarian Parties filed a notice of appeal to the State Court of Appeals, in the ballot access case.

Ohio: on June 6, the Libertarian Party sued the Secretary of State, arguing that it is a qualified party. The case has a hearing in federal court on July 14. Libertarian Party of Ohio v Brunner, 08-391, s.d.

Pennsylvania: on June 2, an independent candidate for State Senate filed a federal lawsuit against petition rules which require rural voters to list their township as part of their mailing address on petitions. Baylor v Cortes, m.d., cv-08-1060.

National: on June 24, the Democratic National Committee sued the Federal Election Commission for failing to adjudicate its complaint against Senator John McCain. The Democrats’ complaint against McCain is that he qualified for primary season matching funds (although he never took the money), and then he broke the law that limits expenditures for candidates who accept public funding. Democratic National Committee v FEC, 1:08-cv-1083, federal court, D.C.

California: on June 18, the State Senate Elections Committee passed AB 583, which establishes a pilot program for public funding. It only applies to the Secretary of State’s race in 2014. Independent candidates need $5 contributions from 15,000 donors, whereas Democrats and Republicans need contributions from 7,500 donors. Those who qualify receive $1,500,000 in public funding.

Colorado: on May 30, Governor Bill Ritter, a Democrat, vetoed HB 1406, which would have made it illegal for out-of-staters to circulate an initiative petition.

Illinois: on June 26, the legislature sent SB 439 to the Governor. It lets municipalities use Instant-Runoff Voting for foreign absentee voters.

Illinois (2): HB 2673, which would have restored the staright-party device, failed to pass.

Congress: Senator Bill Nelson introduced SJR 39 on June 6. It would amend the Constitution to elect the president directly.

On June 12, the Boston Tea Party was approved to send a representative to the national board of the Coalition for Free & Open Elections (COFOE). The Boston Tea Party was formed in 2006 by Libertarians who were unhappy with the Libertarian platform. This year, it is running Charles Jay for president and Tom Knapp for vice-president. It has placed its ticket on the Colorado ballot, but nowhere else so far.

On June 24, the U.S. Senate confirmed five new Federal Election Commissioners, giving the FEC a quorum. The FEC will now be free to certify primary season matching funds to all those who have qualified. The only presidential candidate who is not a Democrat or a Republican, who has qualified for primary season matching funds, is Ralph Nader. He will probably receive approximately $900,000.

Sometimes there isn’t enough money in the Federal Campaign public fund to pay primary season matching funds. However, that is not a problem this year, because the Democratic Party has announced it will not be using general election public funding this year. This is the first time in the history of the public funding program that a major party has declined general election funding. The motivation is that now the Democratic Party can spend as much money on its general election campaign as it wishes.

The FEC is also now free to consider a complaint filed by Nader on May 30, alleging that the Democratic National Committee failed to report several million dollars in expenditures in 2004 for the purpose of trying to keep Nader off ballots. Under a 1980 FEC ruling, expenditures by a party or a political committee to keep someone off the ballot are considered campaign expenditures.

On June 12, Senator John McCain spoke at a town meeting hall in New York city. He took questions from the audience. Frank Morano asked him whether he would participate in at least one debate that includes all presidential candidates who could theoretically win the election (which would mean six people on stage). McCain said, "Maybe we should have one that includes everybody." The event was broadcast on Fox News, but the station was taking a commercial break just then.

This chart covers 1945 through 2007. "State House" means the lower house of the state legislature. When the list of candidates is finalized for 2008, the record in a few states will be broken.

The chart only includes candidates who were on the ballot, not write-in candidates. If a party was the type of party that mostly cross-endorses major party nominees, and mostly doesn’t run its own members, then it is excluded. Specifically, any party for which over half its nominees were also major party nominees (in any given year) is excluded. Otherwise, the Connecticut record would be held by A Connecticut Party in 1992, and the New York record would be held by the Liberal Party in the 1950’s or 1960’s.

The minor party that came closest to running a full slate for lower house of the state legislature was the Colorado Libertarian Party in 2000. The Libertarian Party dominates the chart, holding the record in 23 of the 50 states.

The Alabama record was set by the National Democratic Party of Alabama, a party founded by African-Americans. It was separate from the Democratic Party.

STATE	YEAR	PARTY	NUMBER	VOTE	PERCENTAGE
Alabama	1970	Nat. Dem of Alabama	42 of 106	78,761	21.68
Alaska	1992	Alaskan Independence	17 of 40	11,905	12.14
Arizona	1978	Libertarian	21 of 60	17,016	7.75
Arkansas	1970	American	4 of 100	8,978	11.91
California	1970	American Independent	57 of 80	88,287	1.94
Colorado	2000	Libertarian	57 of 65	119,006	8.35
Connecticut	2004	Working Families	50 of 151	13,830	3.46
Delaware	1970	American	12 of 39	909	1.84
Florida	2002	Libertarian	73 of 120	413,590	13.34
Georgia	2004	Libertarian	4 of 180	3,481	5.11
Hawaii	1976	Indps for Godly Gov’t.	7 of 51	6,618	9.79
Idaho	2002	Libertarian	19 of 70	13,781	9.26
Illinois	2002	Libertarian	10 of 118	23,733	8.13
Indiana	1946	Prohibition	54 of 100	14,509	1.97
Iowa	1966	Conservative	20 of 124	2,538	1.16
Kansas	2006	Libertarian	25 of 125	15,140	8.31
Kentucky	1971	American	6 of 100	1,441	4.58
Louisiana	1972	American	5 of 105	2,998	5.81
Maine	2004	Green	18 of 151	15,831	18.43
Maryland	1970	American	14 of 142	7,783	4.81
Mass.	2000	Libertarian	14 of 160	29,368	12.78
Michigan	1948	Prohibition	49 of 100	8,516	.77
Minnesota	2000	Independence	27 of 134	41,051	9.62
Mississippi	2007	Constitution	3 of 122	2,484	12.77
Missouri	2002	Libertarian	26 of 163	12,576	4.63
Montana	1982	Libertarian	20 of 100	3,920	5.93
Nevada	1980	Libertarian	20 of 40	7,797	6.60
New Hamp	1994	Libertarian	93 of 400	24,370	21.05
New Jersey	1997	Conservative	47 of 80	42,639	2.97
New Mexico	1990	Libertarian	6 of 70	3,806	14.28
New York	1948	American Labor	115 of 150	463,558	8.44
No. Carolina	2002	Libertarian	60 of 120	95,103	8.29
No. Dakota	1976	American	7 of 100	1,988	9.52
Ohio	2000	Libertarian	30 of 99	65,088	4.94
Oklahoma	1984	Libertarian	8 of 101	1,957	2.78
Oregon	2004	Libertarian	18 of 60	25,085	4.80
Pennsylvania	1968	Constitutional	70 of 203	36,141	2.40
Rhode Island	1996	Cool Moose	13 of 100	7,262	15.64
So. Carolina	1970	Independent Party	13 of 124	6,144	4.72
So. Dakota	2006	Libertarian	3 of 70	1,189	4.62
Tennessee	1972	American	8 of 99	8,799	8.85
Texas	2006	Libertarian	88 of 150	231,098	9.05
Utah	1986	Libertarian	35 of 75	6,924	3.58
Vermont	2006	Progressive	17 of 150	14,135	48.65
Virginia	1993	Libertarian	7 of 100	12,443	8.99
Washington	1948	Progressive	48 of 99	14,523	2.93
West Virginia	1998	Libertarian	10 of 100	11,522	11.72
Wisconsin	1972	American	35 of 99	15,131	2.48
Wyoming	1992	Libertarian	6 of 60	1,283	6.51

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB'T	GREEN	CONSTI	NADER	Party	Indp.
Alabama	37,513	5,000	0	0	0	*5,500	June 3	Sep. 8
Alaska	(reg) 7,124	#3,128	already on	*0	already on	2,000	Aug. 6	Aug. 6
Ariz.	20,449	#21,759	already on	already on	*too late	*already on	Mar. 6	June 4
Arkansas	10,000	#1,000	already on	already on	already on	*200	June 30	Aug. 4
Calif.	(reg) 88,991	158,372	already on	already on	already on	seek nom	Dec. 31, 07	Aug. 8
Colorado	(reg) 1,000	pay $500	already on	already on	already on	*already on	June 1	June 17
Conn.	no procedure	#7,500	*200	*3,000	*250	*1,250	- - -	Aug. 6
Delaware	(reg) *284	*5,674	already on	already on	already on	seek nom	Aug. 12	July 15
D.C.	no procedure	est. #3,900	*0	already on	*0	*0	- - -	Aug. 19
Florida	be organized	104,334	already on	already on	already on	seek nom	Sep. 2	July 15
Georgia	44,089	#42,489	already on	3,000	0	0	July 8	July 8
Hawaii	663	4,291	already on	already on	already on	already on	Apr. 3	Sep. 5
Idaho	11,968	5,984	already on	0	already on	*200	Aug. 29	Aug. 25
Illinois	no procedure	#25,000	*finished	already on	*finished	*finished	- - -	June 23
Indiana	no procedure	#32,742	already on	*too late	*too late	*too late	- - -	June 30
Iowa	no procedure	#1,500	*100	*150	*200	0	- - -	Aug. 15
Kansas	16,994	5,000	already on	0	*disputed	0	June 2	Aug. 4
Kentucky	no procedure	#5,000	0	0	*1,000	*1,200	- - -	Sep. 2
La.	(reg) 1,000	pay $500	already on	already on	47	0	May 22	Sep. 2
Maine	27,544	#4,000	0	already on	*50	*550	Dec 14, 07	Ag 15
Maryland	10,000	est. 32,500	already on	already on	0	*300	Aug. 4	Aug. 4
Mass.	est. (reg) 40,500	#10,000	*14,000	already on	*4,500	*6,000	Feb. 1	July 29
Michigan	38,024	38,024	already on	already on	already on	seek nom	July 17	July 17
Minnesota	110,150	#2,000	0	0	0	0	July 15	Sep. 9
Mississippi	be organized	1,000	already on	already on	already on	0	Jan. 10	Sep. 5
Missouri	10,000	10,000	already on	0	finished	*10,000	July 28	July 28
Montana	5,000	#5,000	already on	0	already on	0	Mar. 13	July 30
Nebraska	5,921	2,500	*already on	already on	already on	0	Aug. 1	Aug. 26
Nevada	5,746	5,746	already on	already on	already on	*finished	July 3	July 3
N. Hamp.	12,524	#3,000	*already on	0	0	*150	Aug. 6	Aug. 6
New Jersey	no procedure	#800	0	0	*650	*500	- - -	July 28
New Mex.	2,794	16,764	already on	already on	already on	already on	Apr. 1	June 4
New York	no procedure	#15,000	can't start	can't start	can't start	can’t start	- - -	Aug. 19
No. Car.	69,734	69,734	already on	in court	*too late	*too late	May 16	June 12
No. Dakota	7,000	#4,000	already on	0	already on	*1,000	Apr. 11	Sep. 5
Ohio	20,114	5,000	*in court	400	finished	*1,000	Aug 21	Aug. 21
Oklahoma	46,324	43,913	*500	0	0	0	May 1	July 15
Oregon	20,640	18,356	already on	already on	already on	seek nom	Aug. 26	Aug. 26
Penn.	no procedure	#24,666	*finished	*8,000	*4,500	*5,000	- - -	Aug. 1
Rhode Isl.	18,557	#1,000	0	0	0	0	May 30	Sep. 5
So. Caro.	10,000	10,000	already on	already on	already on	*4,000	May 4	July 15
So. Dakota	8,389	3,356	*700	0	already on	*1,500	Mar. 25	Aug. 5
Tennessee	45,254	25	in court	in court	in court	*200	unsettled	Aug. 21
Texas	43,991	74,108	already on	too late	too late	too late	May 26	May 12
Utah	2,000	#1,000	already on	0	already on	*1,200	Feb. 15	Sep. 2
Vermont	be organized	#1,000	already on	0	already on	0	Jan. 1	Sep. 12
Virginia	no procedure	#10,000	*12,000	*6,500	0	*600	- - -	Aug. 22
Wash.	no procedure	#1,000	*250	*0	*0	*100	- - -	July 26
West Va.	no procedure	#15,118	0	already on	*13,000	*18,000	- - -	Aug. 1
Wisconsin	10,000	#2,000	already on	already on	0	0	June 2	Sep. 2
Wyoming	3,868	3,868	already on	0	*1,400	*4,500	June 2	Aug. 25
TOTAL STATES ON			*31	22	*20	*4	~	~

#partisan label is OK (other than "independent").
*change since June 1 B.A.N.
"Nader" column is independent petitions, except in Hawaii and New Mexico it is the Independent Party.
"Seek nom" means he seeks the nomination of a ballot-qualified party.

The Socialist Party presidential candidate is on the ballot in Colorado and Vermont. The Party for Socialism and Libertarian candidate is on in Colorado, Utah, and Vermont. The Socialist Workers Party candidate is on in Colorado, Delaware, and New Jersey. The Prohibition Party candidate is on in Colorado and Florida.

On June 17, Maryland held a special election to fill the vancant U.S. House seat, 4^th district. The results: Democatic 81.0%, Republican 17.9%, Libertarian 1.1%. When this district voted in November 2006, the results had been: Democratic 81.2%, Republican 18.8%.

The Reform Party will hold a national convention in Dallas on July 18-20. The convention is under the control of a professional parliamentarian, Kay Crews, who was appointed by a state court in Texas. States that were affiliated with the Reform Party as of 2003 may send delegates. Some Reform Party activists have filed a lawsuit in New York to de-legitimize the Dallas convention. McKay v Crews, 10^th district, Supreme Court, 08-20742.

On May 31, the Reform Party of Kansas, which is on the ballot, held a state convention. It nominated presidential electors pledged to Chuck Baldwin for president. Baldwin is also the Constitution Party’s presidential candidate. The Constitution Party is not ballot-qualified in Kansas, so this is welcome news for the Baldwin campaign.

The Secretary of State seems to believe that a Kansas political party may not make its own decision about whom to nominate for president. He seems to believe that the state party must nominate the presidential candidate chosen at a national convention, even though no Kansas law says this. The Reform Party submitted its paperwork on June 27, and will soon hear back from the Secretary of State. In 1980, the American Party of Kansas chose its own presidential candidate, Frank Shelton, even though the national convention of that party had chosen Percy Greaves.

On May 29, Anthony Pollina, state chair of the Vermont Progressive Party, held a press conference to say he will remain in the gubernatorial race. Some had thought he would withdraw, because earlier in May, the Democrats had found a candidate to run for Governor. The Vermont Progressive Party is the nation’s strongest minor party, with six state legislators. Pollina polled 24.8% for Lieutenant Governor in 2002, against both major parties.

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