Federal Election Commission v. Massachusetts Citizens for Life

Massachusetts Citizens for Life (MCFL) (defendant) was a nonprofit organization incorporated to “defend the right to life of all human beings, born and unborn, through educational, political and other forms of activities. . . .” In September 1978, MCFL published a special-edition newspaper directing readers to vote for pro-life candidates whose views aligned with MCFL. The special edition was mailed for free to over 5,000 contributors and over 50,0000 sympathizers. MCFL spent over $9,800 from its general treasury to finance the special edition. The Federal Elections Committee (FEC) (plaintiff) received a complaint alleging that MCFL’s special edition violated § 441b of the Federal Election Campaign Act (FECA), which prohibited an expenditure from a corporate treasury to fund the distribution of campaign materials on behalf of certain candidates to the public. The FEC asserted, and MCFL contested, that MCFL made the remainder of the 100,000 copies of the special edition available to the public. The FEC sued MCFL. The federal district court granted MCFL’s motion, holding that the special edition was not an expenditure under § 441b and was exempted under § 431(9)(B)(i). The district court also held that if § 441b applied to MCFL, it was a violation of the First Amendment. The United States Court of Appeals for the First Circuit held that FECA applied to MCFL but affirmed the district court’s holding that FECA was applied unconstitutionally to MCFL. The Supreme Court of the United States granted certiorari.