Supreme Court of the United States
Austin, Michigan Secretary of State v. Michigan State Chamber of Commerce
March 27, 1990494 U.S. 652
Summary
The Supreme Court held that Michigan's §54(1) campaign finance restriction, which bars corporations from using general treasury funds for independent expenditures in state elections, is constitutional under both the First and Fourteenth Amendments. The Court applied strict scrutiny, finding a compelling state interest in preventing corruption and the distortion of the political process by corporate wealth, and concluded the statute is narrowly tailored. The judgment of the Sixth Circuit was reversed. Justice Scalia dissented, arguing the regulation violates free speech.
Holding
- Whether §54(1) violates the First Amendment.. The restriction on corporate independent expenditures is constitutional because it is narrowly tailored to serve a compelling state interest.
- Whether §54(1) violates the Fourteenth Amendment Equal Protection Clause.. The statute's classifications pass strict scrutiny and do not violate equal protection.
- Constitutionality of the media exemption.. The media exemption is constitutional and does not violate equal protection.
- Whether the statute is overinclusive by covering all corporations.. The statute is not overinclusive; applying to all corporations is justified by the potential for distortion inherent in the corporate form.
- Whether the statute is underinclusive by excluding unincorporated labor unions.. The exclusion of unincorporated unions is justified because they lack the corporate advantages that create the corruption risk.
Docket 88-1569
Cited authorities
- 15 U.S.C. §§ 1801-1804
- 2 U.S.C. §§ 431-455
- 1976 Mich. Pub. Acts 388
- Mich. Comp. Laws § 169.254
- 2 U.S.C. §431
- 15 U.S.C. §§ 1801-1804
- 86 Stat. 11
- 2 U.S.C. §§ 431-455