Scott Gessler

Summary

Justice Hood would have treated the prior federal decision as establishing a broader constitutional boundary for Colorado's campaign-disclosure threshold and would have upheld Rule 4.1's $5,000 threshold as a reasonable implementation of that boundary. He agreed, however, that Rule 4.1.1 was unlawful because the prior decision did not authorize eliminating retrospective reporting. Justice Eid, concurring in part and dissenting in part, likewise rejected the majority's categorical approach but would have invalidated Rule 4.1 only to the extent identified by the court of appeals.