Nixon v. Shrink Missouri Government PAC: Campaign Contributions, Symbolic Speech and the Appearance of Corruption

The purpose of this note is two-fold. First , it reviews pertinent cases and sets forth the appropriate standard of review for contribution limits. Second, it delineates the test that enables government to customize contribution limits to the characteristics of its voting districts without violating the First Amendment. Part II provides a brief history of campaign finance reform, emphasizing limits on campaign contributions. Part III examines the history of campaign contribution limits in Missouri and the Eighth Circuit’s role. Part IV concludes that contribution limits are entitled to a heightened intermediate standard of review. The court should defer to a reasonable legislative determination that the electorate perceives corruption due to large campaign contributions and address two questions to determine if contribution limits are unconstitutionally low: first, whether the limitation impairs a candidate’s ability to amass the resources necessary for an effective campaign; and second, whether the percentage of contributors affected by the limits is within a reasonable range