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Seaton v. Wiener

United States District Court, D. Minnesota

May 19, 2014

Douglas P. Seaton, Van L. Carlson, Linda C. Runbeck, and Scott M. Dutcher, Plaintiffs,
v.
Deanna Wiener, George Beck, Jon Stafsholt, Ed Oliver, Neil Peterson, and Christian Sande, in their official capacities as Chair and members of the Minnesota Campaign Finance and Public Disclosure Board, and Tony Palumbo, and Chad Larson, in their official capacities as county attorneys for Anoka and Douglas Counties, Defendants

Katelynn K. McBride, Esq., Lee U. McGrath, Esq., and Anthony B. Sanders, Esq., Institute for Justice, counsel for Plaintiffs.

Alan I. Gilbert and Jacob D. Campion, Assistant Attorneys General, Minnesota Attorney General's Office, counsel for Defendant.

OPINION

Page 946

MEMORANDUM OPINION AND ORDER

DONOVAN W. FRANK, United States District Judge.

INTRODUCTION

This matter is before the Court on Plaintiffs' Motion for a Temporary Restraining Order and Preliminary Injunction (Doc. No. 6). For the reasons set forth below, the Court grants Plaintiffs' motion.

BACKGROUND

Plaintiffs Linda C. Runbeck, and Scott M. Dutcher (together, the " Candidate Plaintiffs" ) are current and former candidates for Minnesota state office. ( See, e.g., Doc. No. 1, Compl. ¶ ¶ 6-7.) Plaintiff Runbeck is the state representative for Minnesota District 38A and is running for reelection in 2014. ( Id. ¶ 6.) Plaintiff Dutcher ran and lost the state legislative race for Minnesota District 12A in 2012. ( Id. ¶ 7.) Plaintiffs Douglas P. Seaton and Van L. Carlson (together, the " Donor Plaintiffs" ) are campaign donors who " would like to make contributions of more than half the individual contribution limit and to be able to do so without disadvantaging the candidates to whom [they] contribute[]." ( See, e.g., id. ¶ ¶ 4-5.)

At the heart of Plaintiffs' lawsuit is the " special sources" limit set by Minnesota

Page 947

statute. ( Id. ¶ 14.) In particular, Plaintiffs challenge the constitutionality of Minn. Stat. § 10A.27, subd. 11--insofar as it restricts donations from " large contributors" --in light of the recent United States Supreme Court decision, McCutcheon v. Federal Election Commission, 134 S.Ct. 1434, 188 L.Ed.2d 468 (2014). Minn. Stat. § 10A.27, subd. 11, states:

Contributions from certain types of contributors.

A candidate must not permit the candidate's principal campaign committee to accept a contribution from a political committee, political fund, lobbyist, large contributor, or association not registered with the board if the contribution will cause the aggregate contributions from those types of contributors during an election cycle segment to exceed an amount equal to 20 percent of the election cycle segment expenditure limits for the office sought by the candidate, provided that the 20 percent limit must be rounded to the nearest $100. For purposes of this subdivision, " large contributor" means an individual, other than the candidate, who contributes an amount that is more than one-half the amount an individual may contribute during the election cycle segment.

Minn. Stat. § 10A.27, subd. 11. Plaintiffs' Complaint asserts that the special sources limit as applied to " large contributions" violates Plaintiffs' First Amendment rights of free speech and association. ( See Compl. ¶ ¶ 109-14.)

DISCUSSION

I. Standing

Defendants maintain that Plaintiffs lack standing to bring suit against Defendants here. Defendants argue that because the Donor Plaintiffs can right now make, and the Candidate Plaintiffs can right now receive, the campaign contributions at issue under the statute, Plaintiffs have no basis upon which to assert that they have been prevented from exercising their First Amendment rights. Plaintiffs counter that the chilling effect of the statute on First Amendment rights is sufficient to create an injury.

To have standing under Article III of the Constitution, a plaintiff must allege (1) a concrete injury in fact, (2) that is fairly traceable to the challenged action, and (3) that is likely to be redressed by the relief sought. See Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61, 112 S.Ct. 2130, 119 L.Ed.2d 351(1992) (" [T]here must be a causal connection between the injury and the conduct complained of," ...


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