Pollard v. Board of Police Commissioners

WELLIVER, Judge,

dissenting.

I respectfully dissent. After examining the legislative history of the Federal Election Campaign Act of 1974, I believe it is questionable whether Congress intended that Act to preempt all state and local enactments regulating the conduct of state and local government employees in the campaigns of federal elective officers. Nevertheless, I believe we should affirm the judgment of the trial court because § 84.830, RSMo 1978, as applied in this case, impinges on rights protected by the First Amendment.

The legislature enacted § 84.830 as a means to eliminate the involvement of Kansas City police officials in campaigns for public office and to prevent the abuses of power which had occurred during an earlier turbulent period of that city’s history. While designed to serve meritorious purposes, it is manifest that the statute also implicates the rights of expression and association protected by the First Amendment. See Buckley v. Valeo, 424 U.S. 1, 21-25, 96 S.Ct. 612, 635-37, 46 L.Ed.2d 659 (1976). Whether the statute constitutes a permissible infringement on these First Amendment rights is determined by weighing the magnitude of the state’s interest in regulating respondent’s conduct. The Fifth Circuit recently articulated a useful method of analysis:

The standard to be applied ... is a function of the severity of impairment of first amendment interests. As the burden comes closer to impairing core first amendment values, ... or impairs some given first amendment value more substantially, ... the requisite closeness of fit of means and end increases according-ly_ [Restrictions on the partisan political activity of public employees and officers, where such activity contains substantial nonspeech elements, ... are constitutionally permissible if justified by a reasonable necessity ... to burden those activities to achieve a compelling public objective.

Wachsmann v. City of Dallas, 704 F.2d 160 (5th Cir.), cert, denied, — U.S.-, *343104 S.Ct. 537, 78 L.Ed.2d 717 (1983), quoting Mortal v. Judiciary Commission, 565 F.2d 295, 300 (5th Cir.1977) (en banc), cert, denied, 435 U.S. 1013, 98 S.Ct. 1887, 56 L.Ed.2d 395 (1978) (emphasis added).

The United States Supreme Court in Buckley v. Valeo recognized that the First Amendment permits reasonable limitations on the right to contribute to election campaigns. Wachsmann v. City of Dallas provides an example of a regulation which permissibly restricts a government employee’s right to make a campaign contribution. The Fifth Circuit there sustained a municipal ordinance prohibiting contributions by city employees to candidates for the city council. The Court identified several special circumstances present in that case that tended to justify the prohibition. First the ordinance proscribed contributions only to a limited category of elective offices. Second, these offices had a close nexus to the government employees affected by the ordinance. Finally, the ordinance left employees with the opportunity to exercise their right to contribute in other elections. The court observed: “But here, while it is absolute, the ban is on contributions in a particular type of election, not all elections. It is directly tied to the City’s interest.” 704 F.2d at 174. The Fifth Circuit expressed a similar view in Bruno v. Gar-saud, 594 F.2d 1062, 1064 (5th Cir.1979).

In contrast to the ordinance in Wa-chsmann, § 84.830 would appear to prohibit contributions in all campaigns, be they for local, state or federal office. For this reason, I believe we must hold the statute unconstitutional as applied in this case unless the state demonstrates that it is necessary for achieving compelling governmental objectives. In my opinion, the state’s interest may be sufficiently compelling to warrant a prohibition on contributions to candidates for state office, as well as candidates for city office. But this is not the question before us. Our concern here is finding a state interest in totally prohibiting campaign contributions to candidates for federal office. I fail to see what deleterious effects would result from a contribution to a candidate for Congress by a Kansas City police officer or, for that matter, by a judge of this Court. The potential for abuses of the kind § 84.830 was designed to correct simply is not that great in the case of candidates for federal office. Therefore, I believe the state’s interest does not rise to the level of being “compelling” with respect to such campaigns. Given the protected nature of the rights at stake in this case, Buckley v. Valeo, supra, I believe the principal opinion accords the legislature far too much discretion in determining the means to be used to accomplish its purpose. For the foregoing reasons, I too would hold § 84.830, insofar as it totally prohibits contributions to a candidate for federal office, unconstitutional as applied.