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On April 19, 2015, the United States Supreme Court handed down their decision in Williams-Yulee v. The Florida Bar, upholding The Florida Bar rule barring candidates for judicial offices from directly soliciting campaign donations. The Supreme Court’s 5-4 decision saw Chief Justice John Roberts join Justices Sotomayor, Kagan, Ginsburg, and Breyer in rebuking the appellants claim that the restriction violated her First Amendment right to Freedom of Speech. This decision on face value bucks the recent trend of the Court of “invalidating and modifying overreaching campaign finance regulations by citing infringement of protected speech.”
The case will likely have little to no impact on this general direction of the court, exemplified in Citizens United v. Federal Election Commission, 558 U.S. 310 (2010), and McCutcheon v. Federal Election Commission, 134 S. Ct. 1434 (2014). The ruling in Williams-Yulee, while apparently in favor of certain limits on a certain type of campaign donations, is so narrowly applicable to the situation of the case at issue, and so narrowly held at 5-4, that it practically illuminates the outer limits on campaign finance and political speech acceptable by this court as being only slightly beyond none at all.