High Court Rejects Extension of Citizens United

The U.S. Supreme Court has declined an opportunity to extend its landmark Citizens United campaign finance decision by striking down Massachusetts’ ban on corporations making direct contributions to political campaigns.

Two Massachusetts companies had asked the Supreme Court to review their First Amendment challenge to the state ban, arguing the 2010 Citizens United ruling trumps an earlier decision — Federal Election Commission v. Beaumont — that rejected a challenge to the similar federal ban.

But in an unsigned order, the high court on Monday left intact the Massachusetts Supreme Judicial Court’s decision that found the state ban was constitutional, in part because it serves the important purpose of preventing corruption and the appearance of corruption in elections.

“Both history and common sense have demonstrated that, when corporations make contributions to political candidates, there is a risk of corruption, both actual and perceived,” the state court ruled in the case brought by 1A Auto Inc. and 126 Self Storage.

The two companies contended the ban imposed an unconstitutional restraint on their First Amendment rights to free speech and association and denied them their right to equal protection under the law by prohibiting them — and not other entities such as labor unions — from making contributions.

All federal candidates are currently barred from accepting political donations directly from corporations, while Massachusetts and 21 other states also ban corporate contributions.

In Citizens United, the Supreme Court addressed “independent” campaign expenditures, allowing corporations for the first time to contribute to political action committees. 1A Auto and 126 Self Storage argued that the Beaumont decision conflicted with Citizens United and should be overruled.

The Supreme Court “has repudiated key premises of [Beaumont’s] reasoning in more recent decisions that have limited the interests that … have provided stronger protection for political speech by corporations,” they said in their petition for review.

In rejecting that argument, the Massachusetts high court said Citizens United “reaffirmed the key distinction between contributions and independent expenditures, emphasizing that contributions present a special risk of quid pro quo contributions because, unlike independent expenditures, they are coordinated with candidates.”