Order Code IB98025
Issue Brief for Congress
Received through the CRS Web
Campaign Finance:
Constitutional and Legal
Issues of Soft Money
Updated January 30, 2003
L. Paige Whitaker
American Law Division
Congressional Research Service ˜ The Library of Congress

CONTENTS
SUMMARY
MOST RECENT DEVELOPMENTS
BACKGROUND AND ANALYSIS
Definitions of Hard and Soft Money in Federal Elections
Political Party Soft Money
Soft Money Spent On Issue Advocacy
Issue Advocacy Distinguished from Independent Expenditures
Corporate and Labor Union Soft Money
Bipartisan Campaign Reform Act of 2002 (BCRA) (P.L. 107-155) (enacted on March
27, 2002 and effective on November 6, 2002)
Political Party Soft Money
Issue Advocacy
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 been a major issue in the
Over the last several election cycles, soft
campaign finance reform debate as such
money spent for issue advocacy communica-
funds, before enactment of the Bipartisan
tions gained great popularity. Issue advocacy
Campaign Reform Act of 2002 (BCRA) [P.L.
typically occurs when a group, such as a for-
107-155], were generally unregulated and
profit or non-profit corporation or labor orga-
perceived as resulting from loopholes in the
nization, pays for an advertisement that could
Federal Election Campaign Act (FECA).
be interpreted to favor or disfavor certain
Generally, the intent of BCRA, which amends
candidates, while also serving to inform the
FECA and became effective on November 6,
public about a policy issue. BCRA regulates
2002, is to restrict the raising and spending of
in this area by prohibiting corporations and
soft money. This Issue Brief discusses consti-
labor unions from directly funding broadcast
tutional and legal issues surrounding two
advertisements that “mention” a federal candi-
major types of soft money that BCRA seeks to
date 60 days before a general election and 30
regulate: political party soft money and soft
days before a primary and by requiring disclo-
money used for issue advocacy communica-
sure of all such ads regardless of the source of
tions. Corporate and labor union soft money,
funding. The prevailing view in the lower
which FECA expressly exempts from regula-
courts is that Supreme Court precedent gener-
tion and is not addressed by BCRA, is also
ally holds that regulation of such communica-
discussed.
tions, which do not contain specific express

words of advocacy, is unconstitutional. Like-
Prior to BCRA, political party soft
wise, plaintiffs in the pending lawsuit chal-
money was those funds raised by the national
lenging BCRA, McConnell v. FEC, argue that
parties from sources and in amounts that
issue ads are constitutionally protected speech
FECA otherwise prohibited. Such funds were
and may not be regulated.
used in part for overhead expenses and issue
ads, and then largely transferred to state and
Finally, soft money can be used to pay
local parties, in accordance with the applicable
for certain corporate and labor union activities
state law, for grassroots and party building
that are expressly exempt from FECA regula-
activity. As a result of BCRA, FECA now
tion: (1) communications by a corporation di-
generally prohibits national party committees
rected at stockholders, executive or adminis-
from raising or spending soft money, i.e.
trative personnel and their families or by a
funds raised and outside the restrictions of
labor organization directed at its members and
FECA. Although the courts have not yet ruled
families, on any subject; (2) voter registration
on this issue specifically, in McConnell v.
and get-out-the-vote activities by a corpora-
FEC, (No. 02-CV-0582, D.D.C., 2002)),
tion, directed to its stockholders, executive or
which is currently pending before a three-
administrative personnel and their families, or
judge panel of the U.S. District Court for the
by a labor organization to its members and
District of Columbia, plaintiffs argue that such
their families; and (3) the establishment and
restrictions on political party soft money are
administration of a political action committee
unconstitutional.
(PAC). The recently enacted BCRA does not
address this type of soft money.
Congressional Research Service ˜ The Library of Congress

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MOST RECENT DEVELOPMENTS
On March 27, 2002, President Bush signed into law the Bipartisan Campaign Reform Act
of 2002 (BCRA), (P.L. 107-155), which took effect on November 6, 2002. Primary features
of the law include restrictions on party soft money and issue advocacy. Shortly after its
enactment, Senator Mitch McConnell and others filed suit in U.S. District Court for the
District of Columbia arguing that portions of the new law are unconstitutional. On
December 4 and 5, 2002, oral argument was heard in McConnell v. FEC before a three-judge
panel of the U.S. District Court for the District of Columbia. Under the BCRA expedited
review provision (P.L. 107-155 § 403 (107th Cong.)), the court's decision will be reviewed
directly by the U.S. Supreme Court where a ruling is anticipated by Summer 2003.
BACKGROUND AND ANALYSIS
Definitions of Hard and Soft Money in Federal Elections
Prior to enactment of the Bipartisan Campaign Reform Act of 2002 (BCRA) (P.L. 107-
155), money for election related activities that was generally raised and spent outside of
federal regulation was known as “soft money.” It was raised and spent in a manner that
could affect federal elections, but was unregulated – and legal – since it was not spent
directly for or against specific federal candidates. Generally, the intent of BCRA, which
amends the Federal Election Campaign Act (FECA) and became effective on November 6,
2002, is to restrict the raising and spending of soft money.
The term “hard money,” has typically been 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 constitutional and legal issues surrounding two major types
of soft money that BCRA seeks to regulate: political party soft money and soft money used
for issue advocacy. Corporate and labor union soft money, which FECA expressly exempts
from regulation and BCRA does not address, is also discussed.
Political Party Soft Money
Before the enactment of BCRA, political party soft money funds were raised by the
national parties from sources and in amounts that FECA otherwise prohibited. Such funds
were used in part for party overhead expenses and issue ads, and then largely transferred to
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state and local parties, in accordance with the applicable state law, for grassroots and party
building activity. Since the 1979 FECA Amendments, certain grassroots, voter-registration,
get-out-the-vote, and generic party-building activities were exempt from FECA coverage.
(2 U.S.C. § 431(9)(B)(viii),(ix).) In addition, certain Federal Election Commission (FEC)
advisory opinions permitted soft money for a portion of activities that promoted both federal
and state candidates. Therefore, money raised and spent for these activities was in large part
not regulated and hence, was considered political party soft money.
As a result of BCRA, the FECA now generally prohibits national party committees from
raising or spending soft money. Although the courts have not yet ruled on this issue
specifically, in McConnell v. FEC, (No. 02-CV-0582, D.D.C., 2002)), which is currently
pending before a three-judge panel of the U.S. District Court for the District of Columbia,
plaintiffs argue that such restrictions on political party soft money are unconstitutional
because they violate the rights of free speech and association under the First Amendment.
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
U.S. 1, 25 (1976) (quoting Kusper v. Pontikes, 414 U.S. 51, 57 (1973)).) However, 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.)
Defendants in the pending lawsuit challenging the constitutionality of BCRA,
McConnell v. FEC, (No. 02-CV-0582, D.D.C., 2002)), argue that such restrictions on
political party soft money are constitutional because eliminating political party soft money
by subjecting it to the limits and restrictions of the FECA does not significantly impact
political debate as many other methods of expression under the FECA are still available to
a person seeking to make political contributions. For example, persons can still 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. Defendants also argue that the prohibitions on
political party soft money will 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.)
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In a recent Supreme Court decision, Nixon v. Shrink Missouri Government PAC, (120
S.Ct. 897 (2000)), the Supreme Court upheld a 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.
Soft Money Spent On Issue Advocacy
Over the last several election cycles, soft money spent for issue advocacy
communications gained great popularity. 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. BCRA regulates in this area by prohibiting corporations and
labor unions from directly funding broadcast advertisements that “mention” a federal
candidate 60 days before a general election and 30 days before a primary and by requiring
disclosure of all such ads regardless of the source of funding. The prevailing view in the
lower courts is that Supreme Court precedent requires that only those communications that
expressly advocate the election or defeat of a clearly identified candidate can be
constitutionally regulated; any such communication that does not meet this “express
advocacy” standard is constitutionally protected First Amendment speech, which cannot be
regulated. Hence, issue ads may be paid for with unregulated soft money.
Similar to the prevailing view in the lower courts, plaintiffs in the pending lawsuit
challenging the constitutionality of BCRA, McConnell v. FEC, argue that issue ads are
constitutionally protected speech and may not be regulated. On the other hand, the
defendants generally argue that such restrictions are necessary to regulate “sham issue ads,”
broadcast by corporations and labor unions, which are designed to promote the election or
defeat of a federal candidate.
In Buckley v. Valeo, (424 U.S. 1 (1976)), the Supreme Court generally held that
campaign finance limitations apply to “communications that in express terms advocate the
election or defeat of a clearly identified candidate for federal office.” A footnote to the
opinion provides examples of such “express advocacy”: terms “such as ‘vote for,’ ‘elect,’
‘support,’ ‘cast your ballot for,’ ‘Smith for Congress,’ ‘vote against,’ ‘defeat,’ ‘reject.’” (Id.
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), (479 U.S. 238 (1986)), 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 connection with” any federal election. (Id. at 249-250). 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
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certain politicians.” Instead, the Court found, the publication “in effect” provided a directive
to the reader to vote for the identified candidates and ergo, constituted express advocacy. (Id.
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.)
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. (Id. at 12.) The Fourth Circuit reached a similar conclusion in FEC v.
Christian Action Network,
(92 F.3d 1178 (4th Cir. 1997).)
In Vermont Right to Life Committee v. Sorrell, (216 F.3d 264 (2d Cir. 2000)), the
Second Circuit Court of Appeals 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.
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 (Colorado I), 518 U.S. 604 (1996)(Kennedy, J., concurring in the judgment, dissenting
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in part)), only independent expenditures are subject to the FECA, (2 U.S.C. §§ 431 et seq.)
The Colorado I Court held that the First Amendment would prohibit the application of a
FECA provision, 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. (Colorado I, 518 U.S. at 614-17.)
Since a political committee making independent expenditures, however, is still subject to
FECA restrictions regarding sources and contribution amounts it may receive from a person,
(see, e.g., 11 C.F.R. § 110.0(d)), an independent expenditure is not considered soft money.
In FEC v. Colorado Republican Federal Campaign Committee (Colorado II), (533 U.S.
431 (2001)), the Supreme Court held that a political party’s coordinated expenditures, unlike
genuine independent expenditures, may be limited in order to minimize circumvention of the
Federal Election Campaign Act’s (FECA) contribution limits. While the Court’s opinion in
Colorado I was limited to the constitutionality of the application of FECA’s “Party
Expenditure Provision” (2 U.S.C. § 441a(d)(3)) to an independent expenditure by the
Colorado Republican Party, in Colorado II the Court considered a facial challenge to the
constitutionality of the limit on coordinated party spending. Persuaded by evidence
supporting the FEC’s argument, the Court found that coordinated party expenditures are
indeed the “functional equivalent” of contributions. (Id. at 447.) Therefore, in its evaluation,
the Court applied the same scrutiny to the coordinated “Party Expenditure Provision” that
it has applied to other contribution limits: inquiring whether the restriction is “closely drawn”
to the “sufficiently important” governmental interest of stemming political corruption. (Id.
at 456.) The Court further determined that circumvention of the law through “prearranged
or coordinated expenditures amounting to disguised contributions” is a “valid theory of
corruption.” (Id.) In upholding the limit, the Court noted that “substantial evidence
demonstrates how candidates, donors, and parties test the limits of the current law,” which,
the Court concluded, “shows beyond serious doubt how contribution limits would be eroded
if inducement to circumvent them were enhanced by declaring parties’ coordinated spending
wide open.” (Id. at 457.)
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.) 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 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).)
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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 would simply codify the Beck decision, without expanding on the Court’s
ruling, would appear to be constitutional.
Bipartisan Campaign Reform Act of 2002 (BCRA) (P.L. 107-155)
(enacted on March 27, 2002 and effective on November 6, 2002)

Political Party Soft Money. Prohibits national party committees from soliciting,
receiving, directing, transferring, or spending soft money; generally prohibits spending of
soft money for a “federal election activity” by state and local party committees, including an
association or group of state or local candidates or officials. Prohibits state or local
candidates from using soft money for public communications that promote or attack a clearly
identified federal candidate, but exempts communications referring to a federal candidate
who is also a state or local candidate. Permits state, district or local party committees to use
some funds raised under state law for an allocable share (at a 50-50 hard to soft money ratio)
of voter registration drives in the last 120 days of a federal election, and voter identification,
get-out-the-vote drives, and generic activity if it: (1) does not refer to a federal candidate; (2)
does not pay for a broadcast, cable or satellite communication (unless it refers solely to
state/local candidates); (3) takes no more than $10,000 per year from any person for such
activity (or less, if state law so limits); and (4) uses only funds raised by that party committee
expressly for such purposes, with no transfers from other party committees. Defines “federal
election activity” to include: (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) “public
communications” that refer to a clearly identified federal candidate and promote, support,
attack, or oppose a candidate for that office (regardless of whether it expressly advocates a
vote for or against) or services by a state or local party employee who spends at least 25%
of paid time in a month on activities in connection with a federal election. 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.
Issue Advocacy. Creates a new term in federal election law, "electioneering
communication," which regulates political ads that: "refer" to a clearly identified federal
candidate, are broadcast within 30 days of a primary or 60 days of a general election, and for
House and Senate elections, is “targeted to the relevant electorate.” Generally, it would
require disclosure of disbursements over $10,000 for such communications, including
identification of each donor of $1,000 or more, and prohibits such communications from
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being financed with union or certain corporate funds. With respect to corporate funds, it
exempts Internal Revenue Code § 501(c)(4) or § 527 tax-exempt corporations from making
“electioneering communications” with funds solely donated by individuals who are U.S.
citizens or permanent resident aliens, unless the communication is “targeted,” i.e., it was
distributed from a broadcaster or cable or satellite service and is received by 50,000 or more
persons in the state or district where the Senate or House election, respectively, is occurring.
If the definition of “electioneering communication” is ruled unconstitutional, the Act
provides an alternative definition, based on FEC v. Furgatch, (807 F.2d 857 (9th Cir. 1987)):
a communication promoting, supporting, attacking, or opposing a candidate, regardless of
whether it expressly advocates a vote for or against a candidate and is suggestive of no
plausible meaning other than an exhortation to vote for or against a candidate.
FOR ADDITIONAL READING
CRS Issue Briefs
CRS Issue Brief IB87020. Campaign financing, by Joseph E. Cantor.
CRS Reports
CRS Report RL30582. 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 RL31290. Campaign Finance Bills Passed in the 107th Congress: Comparison
of S. 27 (McCain-Feingold), H.R. 2356 (Shays-Meehan), and Current Law, by Joseph
E. Cantor and L. Paige Whitaker
CRS Report 98-282. Campaign Finance Reform: a Legal Analysis of Issue and Express
Advocacy, by L. Paige Whitaker.
CRS Report RS20849. Campaign Finance Reform: Constitutional Issues Raised by
Disclosure Requirements, by L. Paige Whitaker.
CRS Report RS20854. Campaign Finance Reform and Incentives to Voluntarily Limit
Candidate Spending from Personal Funds: Constitutional Issues Raised by Public
Subsidies and Variable Contribution Limits,
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.
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CRS Report 97-1040. Campaign Financing: Highlights and Chronology of Current Federal
Law, by Joseph E. Cantor.
CRS Report 97-555. Compulsory Union Dues and Agency Fee Objectors, by Gail
McCallion.
CRS Report 96-484. Political Spending by Organized Labor: Background and Current
Issues, by Joseph E. Cantor.
CRS Report RL31288. Soft Money, Allegations of Political Corruption, and Enron, by Jack
Maskell and L. Paige Whitaker.
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]
For access to McConnell v. FEC comprehensive case materials from Stanford Law School:
[http://www.law.stanford.edu/library/campaignfinance/#case]
For ongoing tracking of issue advocacy by the Annenberg Public Policy Center of the
University of Pennsylvania:
[http://www.appcpenn.org/issueads/]
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