Farris v. Seabrook

677 F.3d 858 (2012)

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Farris v. Seabrook

United States Court of Appeals for the Ninth Circuit
677 F.3d 858 (2012)

JC

Facts

The state of Washington enacted various limitations on campaign contributions. One such limitation prohibited contributions over $800 in either monetary or in-kind contributions to political committees making expenditures in recall campaigns. Robin Farris (plaintiff), who led a committee to recall Pierce County Assessor-Treasurer Dale Washam, filed suit against a bevy of Washington officials, including Dave Seabrook (defendant), chair of the Washington State Public Disclosure Commission. Farris argued that the contribution limit was an unconstitutional burden on First Amendment free-speech rights. The state argued that under existing caselaw, even under First Amendment scrutiny, campaign-contribution limitations were legitimate so long as they were closely drawn to match a sufficiently important governmental interest. Existing cases did support limitations in regard to individual candidates or multicandidate political committees. The state further indicated that the government interest implicated was the state’s interest in preventing either the appearance of corruption or actual corruption. Farris noted other cases that had invalidated limitations to committees with tenuous or no connections to specific candidates. It was also significant that under Washington law, after a successful recall campaign, the successor was appointed by a governmental entity previously designated by state law. The trial court granted an injunction for Farris against the limitation, holding that the limitation was not closely drawn to a compelling governmental interest. The state appealed.

Rule of Law

Issue

Holding and Reasoning (Fisher, J.)

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