How did the circuit court decide Buckley v. Valeo ?
The appeals court recognized at the start that the 1974 reforms were an attempt to correct "abuses that have spread over the years to infect the nation's federal election campaigns." It noted that Congress passed the reforms after those abuses became the subject of "momentous revelations" in the 1972 presidential campaign. And it agreed that the reforms served important public interests: "No one can doubt the compelling government interest in preserving the integrity of the system of elections through which citizens exercise the core right of a free democracy."22
Protecting the integrity of elections meant conducting them under "rules of law," rules set out in what the court acknowledged was the most comprehensive set of election reforms Congress had ever passed. It acknowledged, too, that the reforms were so comprehensive as to affect activities protected by the First Amendment, and so put them under "strict judicial scrutiny." All but one disclosure provision survived that scrutiny. The court upheld the rest of the 1974 reforms 7-1.23
The reforms survived because the court held that sufficiently compelling public interests can justify incidental restrictions on First Amendment rights, and because the extent of those restrictions had not yet been clearly defined. They had not been clearly defined because no one knew how the law would work in practice. The court noted several times in its opinion that some of the provisions it found to be constitutional might prove not to be when they were applied. Until then, however, the court said that "these latest efforts on the part of our government to cleanse its democratic processes should at least be given a chance to prove themselves."24
And there was another reason why the appeals court upheld the reforms. The court concluded that they enhanced First Amendment values: "By reducing in good measure disparity due to wealth, the Act tends to equalize both the relative ability of all voters to affect electoral outcomes, and the opportunity of all interested citizens to become candidates for elective federal office."25