Iowa Right to Life Committee Inc. v. Tooker: The Eighth Circuit Ignores Citizens United by Striking Down an Iowa Campaign Finance Disclosure Requirement

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Authors
Sund, J. David
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2015
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INTRODUCTION|In campaign finance law, governments typically enacted restrictions on individual and corporate contributions and expenditures in order to prevent corruption. In recent years, however, courts have scaled back or struck down these restrictions as violating the First Amendment's guarantee of free speech. Courts have looked more favorably on disclosure or reporting requirements because they do not directly inhibit speech.|In Iowa Right to Life Committee, Inc. v. Tooker, a non-profit corporation challenged such a reporting requirement. Iowa Right to Life ("IRTL") challenged an Iowa law that required ongoing reports from an individual or corporation making independent expenditures. The United States Court of Appeals for the Eighth Circuit upheld some portions of the law, but determined the ongoing reports unconstitutionally infringed on IRTL's free speech. The court stated IRTL should not be forced to choose between what it called burdensome regulatory requirements and the exercise of free speech...
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Creighton University School of Law
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