Order Code IB98025
Issue Brief for Congress
Received through the CRS Web
Campaign Finance:
Constitutional and Legal
Issues of Soft Money
Updated February 12, 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
Overview
Select Case Law
Pending Lawsuit: McConnell v. FEC
Soft Money Spent On Issue Advocacy
Overview
Select Case Law
Pending Lawsuit: McConnell v. FEC
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


IB98025
02-12-03
Campaign Finance: Constitutional
and Legal Issues of Soft Money
SUMMARY
Prior to enactment of the Bipartisan
profit or non-profit corporation or labor union,
Campaign Reform Act of 2002 (BCRA), P.L.
pays for an advertisement that could be inter-
107-155, the term “soft money” generally
preted to favor or disfavor certain candidates,
referred to unregulated funds, perceived as
while also serving to inform the public about
resulting from loopholes in the Federal Elec-
a policy issue. BCRA prohibits corporations
tion Campaign Act (FECA), 2 U.S.C. §§ 431
and unions from using treasury funds to fund
et seq. Generally, the intent of BCRA, which
“electioneering communications,” defined as
amends FECA and became effective on No-
broadcast advertisements that “refer to” a
vember 6, 2002, is to restrict the raising and
federal candidate, 60 days before a general
spending of soft money. This Issue Brief
election and 30 days before a primary, and
discusses constitutional and legal issues
regardless of the source of funding, requires
surrounding two major types of soft money
disclosure of an ad’s cost, sponsor, and
that BCRA seeks to regulate: political party
contributors. The prevailing view in the lower
soft money and soft money used for issue
courts is that Supreme Court precedent gener-
advocacy communications. Corporate and
ally holds that regulation of such communica-
labor union soft money, which FECA ex-
tions, which do not contain express words of
pressly exempts from regulation and is not
advocacy, is unconstitutional. Likewise,
addressed by BCRA, is also discussed.
plaintiffs in the pending lawsuit, McConnell v.

FEC, argue that issue ads are constitutionally
Prior to BCRA, political party soft
protected speech and may not be regulated.
money was those funds raised by the national
Defendants, however, maintain that BCRA
parties from sources and in amounts that
provides a constitutional regulation of “sham
FECA otherwise prohibited. Such funds were
issue ads,” which are designed to promote the
used in part for overhead expenses and issue
election or defeat of a federal candidate, and
ads, and then largely transferred to state and
should therefore be subject to regulation.
local parties, in accordance with the applicable
state law, for grassroots and party building
Finally, soft money can be used to pay
activity. As a result of BCRA, FECA now
for certain corporate and labor union activities
generally prohibits national parties from
that are expressly exempt from FECA regula-
raising or spending soft money, i.e. funds
tion: (1) communications by a corporation di-
raised outside the restrictions of FECA.
rected at stockholders, executive or adminis-
Although the courts have not yet ruled on this
trative personnel and their families or by a
issue specifically, in McConnell v. FEC, No.
labor organization directed at its members and
02-CV-0582 (D.D.C. 2002), a three-judge
families, on any subject; (2) voter registration
panel of the U.S. District Court for D.C. is
and get-out-the-vote activities by a corpora-
currently considering the constitutionality of
tion, directed to its stockholders, executive or
the BCRA restrictions on party soft money.
administrative personnel and their families, or
by a labor organization to its members and
Over the last several election cycles, soft
their families; and (3) the establishment and
money spent for issue advocacy communica-
administration of a political action committee
tions gained great popularity. Issue advocacy
(PAC). The recently enacted BCRA does not
typically occurs when a group, such as a for-
address this type of soft money.
Congressional Research Service ˜ The Library of Congress

IB98025
02-12-03
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, No. 02-CV-0582
(D.D.C. consolidated May 13, 2002), 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, the court's decision can be directly appealed to 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” or non-federal funds. Soft money 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), 2 U.S.C. §§ 431 et
seq.
, 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 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.
CRS-1

IB98025
02-12-03
Political Party Soft Money
Overview
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
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 to be used for a portion of activities that promoted
both federal and state candidates. See, e.g., AO 1978-10). Money raised and spent for these
activities was in large part unregulated and hence, was considered political party soft money.
As a result of the BCRA amendments, the FECA now generally prohibits national party
committees from raising or spending soft money by subjecting such funds to the limitations,
prohibitions, and reporting requirements of FECA.
Select Case Law
Although the courts have not yet specifically ruled on the constitutionality of such
restrictions on party soft money, in the landmark Buckley v. Valeo decision, 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. Furthermore, the Buckley Court 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.
In a more recent Supreme Court decision, Nixon v. Shrink Missouri Government PAC,
528 U.S. 377 (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
CRS-2

IB98025
02-12-03
that the Court’s decision undermines free speech protections and will add to the proliferation
of “covert speech” in the form of soft money.
Pending Lawsuit: McConnell v. FEC
In the currently pending lawsuit, McConnell v. FEC, plaintiffs generally argue that the
BCRA restrictions on political party soft money are unconstitutional because they
significantly burden free speech and association rights under the First Amendment, but are
not sufficiently tailored to prevent actual corruption or the appearance thereof. Consolidated
Opposition Brief for Plaintiffs at 14-29, McConnell v. FEC, No. 02-CV-0582 (D.D.C. 2002).
Plaintiffs further maintain that BCRA regulation of the role of national party committees in
state and local elections usurps the states’ power to regulate such elections in violation of the
Tenth Amendment to the Constitution and principles of federalism. Id. at 4-14.
Defendants, however, maintain that the prohibitions on political party soft money will
stem corruption, in actuality and appearance, that result from quid pro quo relationships
between large-dollar soft money contributors and federal office candidates who benefit from
political party soft money expenditures. Defendant-Intervenors’ Excerpts of Brief of
Defendants at 19-44, McConnell v. FEC, No. 02-CV-0582 (D.D.C, 2002). With regard to
BCRA’s impact on state and local parties, defendants argue that the restrictions were enacted
to serve the same anti-corruption and anti-circumvention purposes that informed the FECA’s
restrictions on the national parties and only limit the source and amount of money state
parties can use to pay for federal election activity. Id. at 51-60.
Soft Money Spent On Issue Advocacy
Overview
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. 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, according to most
lower courts, issue ads may be paid for with unregulated soft money.
BCRA prohibits corporations and unions from using treasury funds to fund
“electioneering communications,” defined as broadcast advertisements that “refer to” a
federal candidate, 60 days before a general election and 30 days before a primary, and
regardless of the source of funding, requires disclosure of an ad’s cost, sponsor, and
contributors. P.L. 107-155, §§ 201-204.
Select Case Law
CRS-3

IB98025
02-12-03
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
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, 522 U.S. 810 (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
CRS-4

IB98025
02-12-03
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.
Pending Lawsuit: McConnell v. FEC
Similar to the prevailing view in the lower courts, plaintiffs in the currently pending
lawsuit challenging the constitutionality of BCRA, McConnell v. FEC, argue that issue ads
are constitutionally protected speech that may not be regulated. Plaintiffs maintain that
Buckley and its progeny clearly enunciate the standard that the government may not regulate
political speech beyond express advocacy. Consolidated Opposition Brief for Plaintiffs at
32-41, McConnell v. FEC, No. 02-CV-0582 (D.D.C. 2002).
Defendants, on the other hand, argue that the BCRA restrictions on “electioneering
communications” are necessary to regulate “sham issue ads,” which are intended and
designed to promote the election or defeat of a federal candidate. Defendant-Intervenors’
Excerpts of Brief of Defendants at 66-94, McConnell v. FEC, No. 02-CV-0582 (D.D.C.
2002). Often broadcast by corporations and labor unions, defendants argue that such ads
violate FECA restrictions on corporate and union spending. Id. at 94-119. Therefore,
defendants maintain that BCRA was simply an effort by Congress to repair the “gaping holes
recently opened in FECA’s coverage.” Id. at 106.
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
in part), only independent expenditures are subject to the FECA. 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
CRS-5

IB98025
02-12-03
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).
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.
CRS-6

IB98025
02-12-03
Bipartisan Campaign Reform Act of 2002 (BCRA) (P.L. 107-155)
(enacted on March 27, 2002 and effective on November 6, 2002)
The following summarizes BCRA provisions addressing political party soft money and soft
money spent on issue advocacy.
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," in order
to regulate 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, are “targeted to the relevant electorate.” Generally, it requires disclosure of
disbursements over $10,000 for such communications, including identification of each donor
of $1,000 or more, and prohibits such communications from 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,
CRS-7

IB98025
02-12-03
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 Electronic Briefing Book on Campaign Finance Reform,
[http://www.congress.gov/brbk/html/ebcam1.shtml]
CRS Electronic Briefing Book page, Tax-Exempt 527 Organizations,
[http://www.congress.gov/brbk/html/ebcam32.html]
CRS Issue Briefs
CRS Issue Brief IB87020. Campaign Financing, by Joseph E. Cantor.
CRS Reports
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.
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-8

IB98025
02-12-03
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/]
CRS-9