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Legal Principle at Issue

Did Arizona's public campaign financing system, specifically its matching funds provision, violate the First Amendment's protection of free speech by penalizing independent expenditures?

Action

The Supreme Court held that Arizona's matching funds scheme substantially burdens political speech and is not sufficiently justified by a compelling interest to survive First Amendment scrutiny.

Facts/Syllabus

In 1998, Arizona voters approved a ballot measure known as the Clean Elections Act, which established public financing for state legislative candidates. The goal was to reduce the influence of private money in politics and encourage a wider range of candidates to run for office. Under this system, candidates who agreed to limit their spending in exchange for public funding would receive a fixed amount of state money to run their campaigns. To ensure a fair contest, if a publicly funded candidate’s opponent spent more than a set threshold from private contributions, then the publicly funded candidate would be eligible to receive matching funds.

This system, known as the "matching funds" provision, was intended to level the playing field between candidates with varying levels of financial resources so that wealthy candidates or special interest groups could not dominate elections by outspending their opponents. 

In 2008, plaintiffs filed a lawsuit in the U.S. District Court for the District of Arizona arguing the Clean Elections Act infringed on free speech rights by effectively penalizing candidates or groups engaging in independent spending. The district court sided with the plaintiffs, but that decision was reversed by the U.S. Court of Appeals for the Ninth Circuit on April 12, 2010.