Federal Election Commission v. The Christian Coalition

The Christian Coalition (coalition) (defendant) was a corporation formed by Pat Robertson and Ralph Reed for the purpose of mobilizing voters to elect leaders whose views aligned with those of the coalition. One of the coalition’s functions was to produce and distribute voter guides designed to inform Christian voters of how the views of various political candidates aligned with those of the coalition. The voter guides did not expressly advocate for any candidates, but Republican candidates generally aligned with the coalition’s views on the issues highlighted in the guides. The coalition had an especially close relationship with the 1992 reelection campaign of Republican President George Bush and Vice President Dan Quayle (campaign). Reed and Robertson had insider access to the campaign’s strategy, and the campaign often implemented advice offered by Reed. Reed and Robertson repeatedly told the campaign that the coalition planned to distribute 40 million voter guides, and the campaign was aware that the guides would present Bush and Quayle favorably in comparison to their Democratic opponents. The voter guides likely contained insider information that Reed had gained because of his relationship with the campaign, but the campaign did not discuss the contents of the voter guides with the coalition, nor did it negotiate with the coalition for positive coverage within the voter guides. At one point, the coalition informed the campaign that the coalition needed to raise $500,000 to pay for the voter guides. The campaign did not discuss or negotiate with the coalition about the need for funds; however, President Bush subsequently appeared at a coalition fundraiser. The Federal Election Commission (FEC) (plaintiff) brought an action against the coalition, claiming that the coalition’s voter guides were illegal, in-kind corporate contributions made to the campaign in violation of federal campaign finance laws.