Order Code IB98025
CRS Issue Brief for Congress
Received through the CRS Web
Campaign Finance: Constitutional
and Legal Issues of Soft Money
Updated March 2, 2001
L. Paige Whitaker
American Law Division
Congressional Research Service ˜ The Library of Congress

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CONTENTS
SUMMARY
MOST RECENT DEVELOPMENTS
BACKGROUND AND ANALYSIS
Definitions of Hard and Soft Money in Federal Elections
Political Party Soft Money
Corporate and Labor Union Soft Money
Soft Money Spent On Issue Advocacy
Voter Guides
Issue Advocacy Distinguished from Independent Expenditures
Related FEC Ruling
Selected 107th Congress Legislation
FOR ADDITIONAL READING
CRS Issue Briefs
CRS Reports
Selected World Wide Web Sites

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Campaign Finance: Constitutional
and Legal Issues of Soft Money
SUMMARY
“Soft money” has become a major issue
personnel and their families or by a labor
in the campaign finance debate. It is a highly
organization directed at its members and
controversial issue due to the perception that
families on any subject; (2) nonpartisan voter
soft money may be the largest loophole in the
registration and get-out-the-vote activities by
Federal Election Campaign Act (FECA). Soft
a corporation that are directed to its
money is considered to be funds that are raised
stockholders, executive or administrative
and spent according to applicable state laws,
personnel and their families or by a labor
which FECA prohibits from being spent di-
organization to its members and their families;
rectly on federal elections, but that may have
and (3) the establishment and administration of
an indirect influence on federal elections. This
a political action committee (PAC) or a sepa-
Issue Brief discusses the three major types of
rate segregated fund (SSF).
soft money: political party soft money, corpo-
rate and labor union soft money, and soft
Spending on issue advocacy communica-
money used for issue advocacy communica-
tions is another use of soft money that has
tions.
gained great popularity. Issue advocacy typi-
cally occurs when a group, such as a for-profit
Political party soft money is those funds
or non-profit corporation or labor organiza-
raised by the national parties from sources and
tion, pays for an advertisement that could be
in amounts otherwise prohibited in federal
interpreted to favor or disfavor certain candi-
elections by the FECA. In accordance with
dates, while also serving to inform the public
the applicable state law, it is then largely
about a policy issue. However, unlike commu-
transferred to state and local political parties
nications that expressly advocate the election
for grassroots and party-building activities,
or defeat of a clearly identified candidate,
overhead expenses, and issue ads. Much of
many lower courts have interpreted Supreme
the recent legislation would subject the contri-
Court precedent as deeming issue ads constitu-
butions, expenditures, or transfers of national
tionally protected First Amendment speech,
political parties, for any activity that might
which cannot be regulated. Hence, issue ads
affect the outcome of a federal election, to the
may be paid for with soft money.
limitations, prohibitions, and source restric-
tions of the FECA. Although the courts have
As in the 105th Congress, many of the
not had occasion to address this issue specifi-
106th Congress bills focus on political party
cally, it appears that such a restriction on
soft money—subjecting contributions, expen-
political party soft money would arguably pass
ditures, or transfers of national political parties
constitutional muster.
to the limitations, prohibitions and reporting
requirements of the FECA. Other bills would
Certain corporate and labor union activi-
restrict corporate and labor union soft money.
ties are expressly exempt from regulation
Another major reform proposal would subject
under the FECA and can therefore be paid for
certain types of advocacy communications to
with soft money. These exempt activities are:
FECA regulation, either fully or just insofar as
(1) communications by a corporation directed
disclosure requirements.
at stockholders, executive or administrative
Congressional Research Service ˜ The Library of Congress

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MOST RECENT DEVELOPMENTS
New 527 “Issue Ad” Disclosure Law: On July 1, 2000 P.L. 106-230, (H.R. 4762) was
enacted, which requires disclosure by organizations claiming Internal Revenue Code (IRC)
Section 527 status. The disclosure requirement is triggered by the IRC definition of “exempt
function,” 26 U.S.C. § 527(e): “influencing or attempting to influence the selection,
nomination, election or appointment of any individual” to public office. As the “exempt
function” definition appears broader than the definition of “express advocacy,” i.e. words
expressly advocating the election or defeat of a clearly identified candidate, the IRC
definition arguably encompasses what the courts have defined as First Amendment protected
issue advocacy, which may not be constitutionally permissible to regulate. As a result, a
court could find that P.L. 106-230 unconstitutionally regulates issue advocacy because it
requires public disclosure by Section 527 organizations spending soft money for issue ads.
On August 28, 2000, in the U.S. District Court for the Southern District of Alabama, the
National Federation of Republican Assemblies filed suit alleging that P.L. 106-230 is
unconstitutional under the First and Tenth Amendments.
Court Strikes Down Issue Ad Disclosure Law: On June 14, 2000, the United States
Court of Appeals for the Second Circuit, in Vermont Right to Life Committee v. Sorrell, 216
F.3d 264 (2d Cir. 2000), found that state campaign regulations triggering disclosure and
reporting requirements of speech that “expressly or implicitly advocate[] the success or
defeat of a candidate” were facially invalid under the First Amendment because they would
result in a regulation of constitutionally protected issue advocacy, (emphasis added). In
Vermont, the court held that the Supreme Court in Buckley v. Valeo had established an
“express advocacy standard” in order to insure that regulations were neither too vague nor
intrusive on First Amendment protected issue advocacy. Accordingly, the court determined
that by including the term “implicitly,” the regulations extend to advocacy with respect to
public issues, in violation of the rule enunciated in Buckley and its progeny.
Justice Kennedy Warns Of Soft Money Proliferation: On January 24, 2000, by a 6
to 3 vote, the Supreme Court in Nixon v. Shrink Missouri Government PAC, No. 98-963,
upheld Missouri state campaign contribution limits and reaffirmed its landmark 1976
precedent in Buckley v. Valeo that the government can regulate campaign contributions.
The Court noted that it has consistently found that less justification is required in order to
uphold limits on campaign contributions than is required to uphold limits on campaign
expenditures. In his dissent, however, Justice Kennedy warned that the Court’s decision
undermines free speech protections and will add to the proliferation of “covert speech” in
the form of soft money.
BACKGROUND AND ANALYSIS
Definitions of Hard and Soft Money in Federal Elections
The terms “soft money” and “hard money” are not defined in federal election law or
regulations. However, the FEC broadly describes “soft money” as “funds that are prohibited
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under the Federal Election Campaign Act (FECA), 2 U.S.C. §§ 431 et seq., either because
they come from a prohibited source, see 2 U.S.C. §§ 441b, 441c and 441e, or because the
amount exceeds the contribution limits in 2 U.S.C. § 441a.” Memorandum from Lawrence
M. Noble, General Counsel, FEC to the Commissioners of the FEC (June 6, 1997).
Sometimes referred to as nonfederal funds, soft money often includes corporate and/or labor
treasury funds, and individual contributions in excess of federal limits, which cannot legally
be used in connection with federal elections, but can be used for other purposes. (Federal
Election Commission Twenty Year Report, p. 19 (April 1995)) Similarly, Common Cause
has defined “soft money” as “funds raised by Presidential campaigns and national
congressional political party organizations purportedly for use by state and local party
organizations in non-federal elections, from sources who would otherwise be barred from
making such contributions in connection with a federal election, e.g., from corporations and
labor unions and from individuals who have reached their federal contribution limits.” See
Common Cause v. Federal Election Commission, 693 F.Supp. 1391, 1392 (D.D.C. 1987).
For the purposes of this issue brief, “soft money” will be used to describe funds that are not
subject to regulation under the FECA, but appear to be raised and spent in an attempt to
affect federal elections.
The term “hard money,” also undefined under federal election law and regulations, is
typically used to refer to funds raised and spent in accordance with the limitations,
prohibitions, and reporting requirements of the FECA. See 2 U.S.C. §§ 441a, 441b(a).
Unlike soft money, hard money may be used in connection with a federal election. Under the
FECA, hard money restrictions apply to contributions and expenditures from any “person,”
as defined to include, “an individual, partnership, committee, association, corporation, labor
organization, or any other organization or group of persons, but such term does not include
the Federal Government or any authority of the Federal Government,” 2 U.S.C. § 431(11).
This Issue Brief discusses three major types of soft money: political party soft money,
corporate and labor union soft money, and soft money used for issue advocacy.
Political Party Soft Money
Political party soft money funds are raised by the national parties from sources and in
amounts prohibited in federal elections by the FECA and are then largely transferred, in
accordance with applicable state law, to state and local political parties for grassroots and
party-building activities, overhead expenses, and issue ads. Since the 1979 FECA
Amendments, certain grassroots, voter-registration, get-out-the-vote, and generic party-
building activities are exempt from FECA coverage. 2 U.S.C. § 431(9)(B)(viii),(ix).
Therefore, money raised and spent for these activities is not regulated and hence, is
considered political party soft money.
Although the courts have not had occasion to address this issue specifically, it appears
that subjecting the contributions, expenditures, or transfers of national political parties, for
any activity that might affect the outcome of a federal election, to the limitations, prohibitions,
and reporting requirements of the FECA, would arguably pass constitutional muster.
In the landmark Buckley v. Valeo case, the Supreme Court made it clear that the right
to associate is a “basic constitutional freedom,” and that any action that may have the effect
of curtailing that freedom to associate would be subject to the strictest judicial scrutiny. 424
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U.S. 1, 25 (1976) (quoting Kusper v. Pontikes, 414 U.S. 51, 57 (1973)). But the Court
further asserted that the right of political association is not absolute and can be limited by
substantial governmental interests such as the prevention of corruption or the prevention of
even the appearance of corruption. 424 U.S. at 27-28.
Employing this analysis, the Buckley Court determined that limitations on contributions
can pass constitutional muster if they are reasonable and only marginally infringe on First
Amendment rights in order to stem actual or apparent corruption resulting from quid pro quo
relationships between contributors and candidates. The Court noted that, unlike an
expenditure limitation, a reasonable contribution limitation does “not undermine to any
material degree the potential for robust and effective discussion of candidates and campaign
issues by individual citizens, associations, the institutional press, candidates, and political
parties.” 424 U.S. at 20-38.
It could be argued that eliminating political party soft money by subjecting it to the limits
and restrictions of the FECA would not significantly impact political debate because many
other methods of expression under the FECA would still be available to a person seeking to
make political contributions. For example, persons could: contribute directly to a candidate,
to a PAC that would support a certain candidate, to the political party of such a candidate in
accordance with FECA-regulated contribution limits (also known as “hard money”
contributions), to state parties for state activities, or make independent expenditures on behalf
of the candidate. It could be further argued that prohibiting political party soft money would
stem corruption or the appearance thereof that could result from quid pro quo relationships
between large-dollar soft money contributors and federal office candidates who benefit from
political party soft money expenditures. The Court in Buckley found that preventing
corruption or the appearance thereof, which can be presented by such quid pro quo
relationships, would constitute a substantial governmental interest warranting reasonable
infringement on First Amendment rights. 424 U.S. 26-27. Hence, under Buckley, it appears
that a prohibition on political party soft money could arguably pass constitutional muster.
The FEC reported on March 19, 1997, that during the 1995-96 election cycle,
Republican national committees had raised $138.2 million for their non-federal or soft money
accounts and spent $149.7 million, an increase of 178% and 224%, respectively, over this
same time period in the 1991-92 election cycle. The Democratic national committees raised
$123.9 million and spent $121.8 million in that same period, a 241% increase in receipts in
their soft money accounts and a 271% jump in spending from the 1992 cycle.

On November 18, 1998, the Federal Election Commission held a public hearing
regarding a Notice of Proposed Rulemaking to prohibit national political parties from raising
or spending soft money. The Notice of Proposed Rulemaking was published in the July 13,
1998 Federal Register and the FEC is currently reviewing comments received.
Corporate and Labor Union Soft Money
Generally, contributions and expenditures by corporations, labor unions, membership
organizations, cooperatives, and corporations without capital stock have been prohibited in
federal elections. 2 U.S.C. § 441b. The FECA, however, provides for three exemptions from
this broad prohibition, that is, contributions and expenditures for: (1) communications by a
corporation to its stockholders, executive or administrative personnel and their families or by
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a labor organization to its members or families on any subject; (2) nonpartisan voter
registration and get-out-the-vote activities by a corporation aimed at its stockholders and
executive and administrative personnel and their families or by a labor organization aimed at
its members and their families; and (3) the establishment, administration and solicitation of
contributions to a separate segregated fund (commonly known as a political action committee
or PAC or SSF) to be utilized for federal election purposes by a corporation, labor
organization, membership organization, cooperative, or corporation without capital stock.
2 U.S.C. § 441b(b)(2)(A)-(C); see also 11 C.F.R. § 114.1(a)(2)(i)-(iii).
In Communication Workers of America v. Beck, 487 U.S. 735 (1988), the Supreme
Court held that labor unions are not permitted to spend funds exacted from dues-paying
non-union employees under an agency shop agreement for certain activities unrelated to
collective bargaining when those employees object to such expenditures. According to the
Court, Congress’ purpose in providing the union shop was to force employees to bear their
fair share of the costs of labor-management negotiations and collective bargaining activities,
but not to force employees to support unrelated labor union political activities they oppose.
As a result of Beck, non-union employees in an agency shop agreement can request a refund
of that portion of their dues used by the union for political activities. Accordingly, if workers
exercise their rights under Beck, labor unions would lose some soft money funds, which
would otherwise be available for election-related expenses. Campaign finance reform
legislation that simply codifies the Beck decision, without expanding on the Court’s ruling,
would appear to be constitutional.
Soft Money Spent On Issue Advocacy
Spending on issue advocacy communications is another use of soft money that has
gained popularity in recent federal election cycles. Issue advocacy communications are paid
for by a group, such as a for-profit or non-profit corporation or labor organization, for
advertisements that could be interpreted to favor or disfavor certain candidates, while also
serving to inform the public about a policy issue. The Supreme Court has ruled that unlike
communications that expressly advocate the election or defeat of a clearly identified
candidate, issue ads are constitutionally protected First Amendment speech and cannot be
regulated. Hence, they may be paid for with unregulated soft money.
Court Decisions
In Buckley v. Valeo, 424 U.S. 1 (1976), the Supreme Court held that campaign finance
limitations apply only to “communications that in express terms advocate the election or
defeat of a clearly identified candidate for federal office.” A footnote to the opinion says that
the limits apply when communications include terms “such as ‘vote for,’ ‘elect,’ ‘support,’
‘cast your ballot for,’ ‘Smith for Congress,’ ‘vote against,’ ‘defeat,’ ‘reject.’” Buckley, supra
at 44 n.52; See 11 C.F.R. 101.22(a). Communications without these ‘magic words’ are often
classified as issue advocacy, thus falling outside the scope of the FECA.
In the 1986 decision of Federal Election Commission v. Massachusetts Citizens for Life,
Inc., (MCFL), the Supreme Court continued to distinguish between issue and express
advocacy, holding that an expenditure must constitute express advocacy in order to be subject
to the FECA prohibition against corporate use of treasury funds to make an expenditure “in
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connection with” any federal election. 479 U.S. 238, 249-250 (1986). In MCFL, the Court
ruled that a publication urging voters to vote for “pro-life” candidates, while also identifying
and providing photographs of certain candidates who fit that description, could not be
regarded as a “mere discussion of public issues that by their nature raise the names of certain
politicians.” Instead, the Court found, the publication effectively provided a directive to the
reader to vote for the identified candidates and ergo, constituted express advocacy. 479 U.S.
at 249-250.
In FEC v. Furgatch, 807 F.2d 857 (9th Cir. 1987), cert. denied, 484 U.S. 850 (1987),
the Ninth Circuit presented the following three-part test to determine whether a
communication may be considered issue advocacy:
First, even if it is not presented in the clearest, most explicit language, speech is ‘express’
for the present purposes if its message is unmistakable and unambiguous, suggestive of
only one plausible meaning. Second, speech may only be termed ‘advocacy’ if it presents
a clear plea for action, and thus speech that is merely informative is not covered by the Act.
Finally, it must be clear what action is advocated. Speech cannot be ‘express advocacy of
election or defeat of a candidate’ when reasonable minds could differ as to whether it
encourages a vote for or against a candidate or encourages the reader to take some other
kind of action. Id. at 864.
On July 6, 1995, the FEC promulgated regulations defining “express advocacy” in a manner
consistent with the test espoused in Furgatch. 60 Fed. Reg. 35292, 35304 (codified at 11
C.F.R. 100.22) (effective Oct. 5, 1995. 60 Fed. Reg. 52069 (Oct. 5, 1995).
However, the trend in the circuit courts appears to be away from the Furgatch and FEC
definitions toward a more limited interpretation of what type of speech will constitute
“express advocacy.” Hence, regulation of fewer types of communications are being upheld
as constitutionally permissible and therefore, more “issue ads” are permissibly funded with
soft money.
In Maine Right to Life Committee v. FEC, 914 F.Supp. 8 (D. Maine 1996), aff’d per
curiam 98 F.3d 1 (1st. Cir. 1996), cert. denied, 118 S.Ct. 52 (Oct. 6, 1997), the First Circuit
affirmed the district court’s opinion that the FEC surpassed its authority when it included a
“reasonable person” standard in its definition of “express advocacy.” The court reasoned that
such a standard threatened to infringe upon issue advocacy, an area protected by the First
Amendment. Maine Right to Life, 914 F.Supp. at 12. The Fourth Circuit reached a similar
conclusion in FEC v. Christian Action Network, 92 F.3d 1178 (4th Cir. 1997). Most recently,
on June 14, 2000, the Second Circuit, in Vermont Right to Life Committee v. Sorrell, 216
F.3d 264 (2d Cir. 2000), found that state campaign regulations triggering disclosure and
reporting requirements of speech that “expressly or implicitly advocate[] the success or defeat
of a candidate” were facially invalid under the First Amendment because they would result
in a regulation of constitutionally protected issue advocacy, (emphasis added). In Vermont,
the court held that the Supreme Court in Buckley had established an “express advocacy
standard” in order to insure that regulations were neither too vague nor intrusive on First
Amendment protected issue advocacy. Accordingly, the court held that by including the term
“implicitly,” the regulations extend to advocacy with respect to public issues, in violation of
the rule enunciated in Buckley and its progeny.
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Nevertheless, the FEC has declined to revise its regulations defining “express advocacy.”
See 63 Fed. Reg. 8363 (Feb. 19, 1998). The FEC has stated that its primary reason for this
decision is “its belief that the definition of ‘express advocacy’ found at 11 CFR 100.22(b) is
constitutional.” Id. at 8264.
Voter Guides
Another form of issue advocacy that has been widely used is the distribution of “voter
guides.” The distribution of voter guides by the Christian Coalition between 1990 and 1994
is currently at issue in FEC v. Christian Coalition, No.96 CVO 1781 (D.D.C.July 30, 1996).
One argument being made by the FEC is that since these voter guides declare candidates’
stands on issues as either “good” or “misguided,” the Christian Coalition is expressly
advocating the election of candidates from a particular party. Thus, the FEC argues, the
Christian Coalition is making independent expenditures that are subject to FECA reporting
requirements.
Issue Advocacy Distinguished from Independent Expenditures
Soft money spent for issue advocacy communications is sometimes confused with
independent expenditures. Although both types of expenditures are purportedly independent
(Justice Kennedy argues that, by nature, practically all expenditures are coordinated with a
candidate and, thus, cannot be considered independent. Colorado Republican Committee v.
FEC, 518 U.S. 604(1996) (Kennedy, J., concurring in the judgment, dissenting in part)), only
independent expenditures are subject to the FECA. 2 U.S.C. §§ 431 et seq. The Colorado
Court held that the First Amendment would prohibit the application of the provision in the
FECA, 2 U.S.C. § 441a(d)(3), limiting political party expenditures made independently and
without any coordination with a candidate or his or her campaign. The Colorado decision
essentially banned any limitations on political party expenditures when they are made
independently of a candidate’s campaign. However, since a political committee making
independent expenditures is still subject to FECA restrictions on the sources and the amount
of contributions it may receive from a person, 11 C.F.R. § 110.0(d), an independent
expenditure cannot be considered soft money.
Related FEC Ruling
In a 6-0 vote, on December 10, 1998, the Federal Election Commission rejected its
auditors’ recommendation that the 1996 Clinton and Dole campaigns repay $7 million and
$17.7 million, respectively, because the national political parties had closely coordinated their
soft money issue ads with the respective presidential candidates and, accordingly, the
expenditures would be counted against the candidates’ spending limits.
Selected 107th Congress Legislation
H.R. 380 (Shays-Meehan)
Party Soft Money. Prohibits national party and federal candidate committees from
raising soft money. Restricts state party committees from spending soft money for “federal
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election activity,” including: (1) voter registration drives in last 120 days of a federal election;
(2) voter identification, get-out-the-vote drives, and generic activity in connection with an
election in which a federal candidate is on the ballot; and (3) communications that refer to a
clearly identified federal candidate with intent of influencing that election (regardless of
whether it is express advocacy); allows state party spending on specific activities exclusively
devoted to non-federal elections; bans party committees’ use of soft money to raise funds;
prohibits federal candidates, officeholders, and their PACs from raising soft money in
connection with a federal election, or money from sources beyond federal limits and
prohibitions in non-federal elections; requires disclosure by national parties of all activity
(federal and non-federal) and by state and local parties of specified activities that might affect
federal elections; removes building fund exemption.
Corporate/Labor Soft Money. Requires labor unions, corporations, and national banks
to disclose promptly all exempt activities (but only internal communications referring to
federal candidates) once threshold level is reached; requires labor unions to give reasonable
notice to dues-paying non-members of rights to disallow political use of their funds.
Issue Advocacy. Defines “express advocacy” communications as advocating the
election or defeat of a candidate by (1) using explicit phrases, or words or slogans that in
context can have no other reasonable meaning than election advocacy; (2) referring to a
candidate in a paid radio or television broadcast ad that appears in the affected state within
60 days of the election (or, for president and vice president, within 60 days of a general
election, regardless of where it appears); or (3) expressing unmistakable, unambiguous
election advocacy, when taken as a whole and with limited reference to external events.
Exempts from “express advocacy” definition printed or internet voting guides and records of
at least one candidate (but would allow inclusion of statements of agreement or disagreement
with candidate positions) that are not coordinated with a candidate or party (but allows
questions to and responses from candidates regarding guides) and that contain no words or
phrases that in context have no reasonable meaning other than election advocacy. Amends
definition of “expenditure” under FECA to include a payment (1) for a communication
containing express advocacy, and (2) for a communication that refers to a clearly identified
candidate, in coordination with a candidate or his or her agent or party, for the purpose of
influencing a federal election. Prohibits publicly-funded presidential candidates from
coordinating issue advocacy with parties, if paid for with soft money. Prohibits consideration
of background music (but not lyrics) in determining whether an advertisement constituted
express advocacy.
Introduced January 31, 2001; jointly referred to Committees on House Administration,
Education and the Workforce, Government Reform, Judiciary, Ways and Means, and Rules.
S. 27 (McCain-Feingold)
Party Soft Money. Prohibits national party committees from soliciting, receiving,
directing, transferring, or spending soft money; prohibits state and local party committees
from spending soft money for “federal election activity,” including: (1) voter registration
drives in last 120 days of a federal election; (2) voter identification, get-out-the-vote drives,
and generic activity in connection with an election in which a federal candidate is on the
ballot; and (3) communications that refer to a clearly identified federal candidate with intent
of influencing that election (regardless of whether it is express advocacy); allows state party
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spending on specific activities exclusively devoted to non-federal elections; bans party
committees’ use of soft money to raise funds; prohibits federal candidates, officeholders, and
their PACs from raising soft money in connection with a federal election, or money from
sources beyond federal limits and prohibitions in non-federal elections; requires disclosure by
national parties of all activity (federal and non-federal) and by state and local parties of
specified activities that might affect federal elections; removes building fund exemption.
Corporate/Labor Union Soft Money. Requires labor unions to give reasonable notice
to dues-paying non-members of rights to disallow political use of their funds.
Issue Advocacy. Requires disclosure of “electioneering communications” above
$10,000, with identification of donors of $500 or more. Prohibits funding of electioneering
communications with union or for-profit corporations funds.
Introduced Jan. 22, 2001; referred to Committee on Rules and Administration.
FOR ADDITIONAL READING
CRS Issue Briefs
CRS Issue Brief 87020. Campaign financing, by Joseph E. Cantor.
CRS Issue Brief 97045. Campaign fundraising controversy and investigation, by Kevin J.
Coleman, Joseph E. Cantor, Jack Maskell, Marie B. Morris, and L. Paige Whitaker.
CRS Reports
CRS Report RL30587. 527 Organizations: How the differences in tax and election laws
permit certain organizations to engage in issue advocacy without public disclosure and
proposals for change, by Marie B. Morris.
CRS Report RS20650. 527 Organizations: Reporting requirements imposed on political
organizations after enactment of P.L. 106-230, by Marie B. Morris.
CRS Report 97-973. Business and labor spending in U.S. elections, by Joseph E. Cantor.
CRS Report RS20346. Campaign finance bills in the 106th Congress: Comparison of Shays-
Meehan, as passed, with McCain-Feingold, as revised, by Joseph E. Cantor.
CRS Report RL30162. Campaign finance bills in the 106th Congress: House, by Joseph E.
Cantor.
CRS Report RL30166. Campaign finance bills in the 106th Congress: Senate, by Joseph E.
Cantor.
CRS Report RL30299. Campaign finance debate in the 106th Congress: Comparison of
measures under House consideration, by Joseph E. Cantor.
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CRS Report 98-282. Campaign finance reform: A legal analysis of issue and express
advocacy, by L. Paige Whitaker.
CRS Report RL30669. Campaign finance regulation under the First Amendment: Buckley
v. Valeo and its Supreme Court progeny, by L. Paige Whitaker.
CRS Report 97-1040. Campaign financing: Highlights and chronology of current federal
law, by Joseph E. Cantor.
CRS Report 97-816. Campaign fund-raising controversy and investigation: A Chronology,
by Kevin J. Coleman.
CRS Report 97-555. Compulsory union dues and agency fee objectors, by Gail McCallion.
CRS Report 96-929. Independent expenditures by political parties: Colorado Republican
Federal Campaign Committee v. Federal Election Commission, by John Contrubis.
CRS Report 96-484. Political spending by organized labor: Background and current issues,
by Joseph E. Cantor.
CRS Report 97-91. Soft and hard money in contemporary elections: What federal law does
and does not regulate, by Joseph E. Cantor.
CRS Report 97-618. The use of union dues for political purposes: A legal analysis, by L.
Paige Whitaker.
Selected World Wide Web Sites
Federal Election Commission:
[http://www.fec.gov]
For access to full text of court decisions:
[http://www.findlaw.com/casecode/cases.html]
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