The Supreme Court's decision in Buckley v. Valeo partially dismantled the electoral reform program formulated in the 1974 Amendments to the Federal Election Campaign Act of 1971. The Court declared that the Act's limitations on expenditures by candidates and independent expenditures in federal elections unconstitutionally burdened political speech and association, while it upheld restrictions on contributions to candidates. After five months of deliberation, Congress attempted to salvage its design for electoral reform by enacting the Federal Election Campaign Act Amendments of 1976. Responding to Buckley's approval of restrictions on political contributions, Congress imposed new limits on "contributions" to political committees. This note argues that, under the framework of analysis employed by the Court in Buckley, the 1976 Amendments' limitations on contributions to political committees are unconstitutional.
The unConstitutionality of Limitations upon Donations to Political Committees in the 1976 Federal Election Campaign Act Amendments, 86 YALE L.J. 953