The Michigan Campaign Finance Act prohibited corporations from using treasury money for independent expenditures to support or oppose candidates in elections for state offices. However, if a corporation set up an independent fund designated solely for political purposes, it could make such expenditures. The law was enacted with the assumption that "the unique legal and economic characteristics of corporations necessitate some regulation of their political expenditures to avoid corruption or the appearance of corruption." The Michigan Chamber of Commerce wanted to support a candidate for Michigan's House of Representatives by using general funds to sponsor a newspaper advertisement.
Did the Michigan Campaign Finance Act violate the First and Fourteenth Amendments?
No. In making its case, the Michigan Chamber of Commerce argued that it should have been excluded from the act's restrictions since the Chamber was a "nonprofit ideological corporation" which was more analogous to a political association than a business firm. The Court disagreed and upheld the Michigan law. Justice Marshall found that the Chamber was akin to a business group given its activities, linkages with community business leaders, and high degree of members (over seventy-five percent) which were business corporations. Furthermore, Marshall found that the statute was narrowly crafted and implemented to achieve the important goal of maintaining integrity in the political process.
Decisions
Decision: 6 votes for Austin, 3 vote(s) against Legal provision: Amendment 1: Speech, Press, and Assembly
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Full Opinion by Justice Thurgood Marshall
