Citizens for Responsibility and Ethics in Washington v. Federal Election Commission

971 F.3d 340 (2020)

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Citizens for Responsibility and Ethics in Washington v. Federal Election Commission

United States Court of Appeals for the District of Columbia Circuit
971 F.3d 340 (2020)

Facts

Crossroads GPS (Crossroads) (defendant) made independent expenditures (IE), which are political advertisements made absent any coordination with a political candidate. Like most IE makers, Crossroads was supported by donations. Under the donor-disclosure rules promulgated by the Federal Election Commission (FEC) (defendant), Crossroads was required to disclose the identity of only those donors who made contributions to support a specific IE, not donors who made general donations. Citizens for Responsibility and Ethics in Washington (CREW) (plaintiff) filed a complaint with the FEC alleging that Crossroads violated donor-disclosure requirements by failing to disclose donations from certain donors. All the donors CREW identified made general contributions to Crossroads. The FEC dismissed the complaint, holding that the FEC’s rules required Crossroads to disclose only the identity of donors who made contributions toward a particular IE. CREW then filed an action against Crossroads in federal court, arguing that the FEC’s donor-disclosure rules were invalid because they conflicted with the unambiguous and substantially broader disclosure requirements mandated by the Federal Election Campaign Act (FECA). The district court allowed Crossroads to intervene as a defendant. The district court then reversed the FEC’s ruling and granted CREW summary judgment, holding that the FEC’s donor-disclosure rules were invalid and that the FEC’s decision to dismiss CREW’s complaint was inconsistent with FECA’s broad donor-disclosure requirements.

Rule of Law

Issue

Holding and Reasoning (Srinivasan, C.J.)

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