United States District Court

District of Columbia

Republican National Committee

310 First Street, SE

Washington, DC 20003

Reince Priebus, as Chairman of the Republican National Committee

310 First Street, SE

Washington, DC 20003

Republican Party of Louisiana

530 Lakeland Drive, Suite 215

Baton Rouge, LA 70802

Jefferson Parish Republican Parish Executive Committee

729 Champagne Drive

Kenner, LA 70065

Orleans Parish Republican Executive

Committee

230 Carondelet Street

New Orleans, LA 70130

Roger Villere, Jr., as Chairman of the Republican Party of Louisiana

530 Lakeland Drive, Suite 215

Baton Rouge, LA 70802,

Plaintiffs

v.

Federal Election Commission

999 E Street, NW

Washington, DC 20463,

Defendant

Civil Case No.

THREE-JUDGE COURT REQUESTED

Verified Complaint for Declaratory and Injunctive Relief

Plaintiffs complain as follows:

Verified Complaint 1

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 1 of 22
Introduction

1. This is a First Amendment constitutional challenge to provisions of the Bipartisan Campaign Reform Act of 2002 (“BCRA”), Pub. L. 107-155, 116 Stat. 81 (Mar. 27, 2002), as codi- 1

fied, relating to:

(a) forming political-party-committee non-contribution accounts (“NCAs”) by national- and 2

state-party committees (Count 1),

(b) solicitation for such NCAs by national-party committee officers and agents (Count 2),

and

(c) independent federal election activity of state- and local-party committees (Count 3). 3

2. Despite having no cognizable anti-corruption interest in restricting independent activities,

the government restricts certain independent activities Plaintiffs wish to do—in challenged

BCRA provisions.

3. The unifying, controlling, legal principle of the counts below is the Supreme Court’s holding, as a matter of law, that “independent expenditures . . . do not give rise to corruption or the

appearance of corruption.” Citizens United v. FEC, 558 U.S. 310, 357 (2010).

4. One application of this principle is that political parties may not be prohibited from making

independent expenditures. Colorado Republican Federal Campaign Committee v. FEC, 518 U.S.

604 (1996). “[T]he constitutionally significant fact . . . is the lack of coordination between the

candidate and the source of the expenditure.” Id. at 617 (Breyer, J., joined by O’Connor &

Souter, JJ.) (“Colorado-I”) (This plurality opinion states the holding. Marks v. United States, 430

Available at http://www.gpo.gov/fdsys/pkg/PLAW-107publ155/pdf/PLAW- 1

107publ155.pdf).

See ¶¶ 5, 21-22 (explaining NCAs). 2

See ¶ 51 (defining “federal election activity”). 3

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U.S. 188, 193 (1977).). “We do not see how a Constitution that grants to individuals, candidates,

and ordinary political committees the right to make unlimited independent expenditures could

deny the same right to political parties.” Colorado-I, 518 U.S. at 618.

5. For example, while nonconnected political committees may establish a non-contribution

account (“NCA”) to receive unlimited contributions to make independent expenditures, a

political-party committee may not establish such an NCA. See FEC, FEC Statement on Carey v.

FEC: Reporting Guidance for Political Committees that Maintain a Non-Contribution Account

(allowing only “nonconnected political committees” to form NCAs). In addition, state- and 4

local-party committees must use “federal funds” for “federal election activity,” e.g., voter-registration and get-out-the-vote activities—even when they are done independently of any federal

candidate. 2 U.S.C. §§ 431(20) (“federal election activity” definition), 441i(b) (prohibition).

“Federal funds mean funds that comply with the limitations, prohibitions, and reporting requirements of the Act.” 11 C.F.R. § 300.2(g). “Non-Federal funds mean funds that are not subject to

the limitations and prohibitions of the Act.” 11 C.F.R. § 300.2(k). Louisiana state-regulated

funds are non-Federal funds.

6. Because Plaintiffs elect the judicial-review provision provided by BCRA § 403, see infra

¶ 7, “[i]t shall be the duty of the United States District Court for the District of Columbia and the

Supreme Court of the United States to advance on the docket and to expedite to the greatest possible extent the disposition of this action and appeal.” BCRA § 403(a)(4) and (d)(2).

7. In relevant part, BCRA § 403, 116 Stat. at 113-14, provides as follows:

SEC. 403. JUDICIAL REVIEW.

(a) SPECIAL RULES FOR ACTIONS BROUGHT ON CONSTITUTIONAL

GROUNDS.—If any action is brought for declaratory or injunctive relief to challenge the

Available at http://www.fec.gov/press/press2011/20111006postcarey.shtml. 4

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constitutionality of any provision of this Act or any amendment made by this Act, the following rules shall apply:

(1) The action shall be filed in the United States District Court for the District of

Columbia and shall be heard by a 3-judge court convened pursuant to section 2284 of

title 28, United States Code.

(2) A copy of the complaint shall be delivered promptly to the Clerk of the House of

Representatives and the Secretary of the Senate.

(3) A final decision in the action shall be reviewable only by appeal directly to the

Supreme Court of the United States. Such appeal shall be taken by the filing of a notice

of appeal within 10 days, and the filing of a jurisdictional statement within 30 days, of

the entry of the final decision.

(4) It shall be the duty of the United States District Court for the District of Columbia and the Supreme Court of the United States to advance on the docket and to expedite to the greatest possible extent the disposition of the action and appeal.

(b) . . . .

(c) . . . .

(d) APPLICABILITY.—

(1) INITIAL CLAIMS.— . . . .

(2) SUBSEQUENT ACTIONS.—With respect to any action initially filed after December 31, 2006, the provisions of subsection (a) shall not apply to any action described in such section unless the person filing such action elects such provisions to

apply to the action.

Jurisdiction and Venue

8. This Court has jurisdiction over this First Amendment challenge under 28 U.S.C. § 1331

and the Declaratory Judgment Act, 28 U.S.C. §§ 2201-02.

9. This Court also has jurisdiction under the judicial-review provisions of BCRA § 403, 116

Stat. at 113-14, see supra ¶ 7, which apply to “any action . . . brought for declaratory or injunctive relief to challenge the constitutionality of any provision of [BCRA] or any amendment made

by [BCRA],” BCRA § 403(a), 116 Stat. at 113-14, because Plaintiffs “elect[] such provisions to

apply to this action,” BCRA § 403(d)(2), 116 Stat. at 114. BCRA § 403 provides for a threejudge court and direct appeal to the United States Supreme Court.

10. Venue is proper under 28 U.S.C. § 1391(e) and BCRA § 403, 116 Stat. at 113-14, see

supra at ¶ 7.

Verified Complaint 4

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Parties

11. Plaintiff Republican National Committee (“RNC”) “ha[s] the general management of the

Republican Party, based upon the rules adopted by the Republican National Convention.” The

Rules of the Republican Party at Rule 1. RNC is a “national committee,” which “by virtue of the

bylaws of a political party, is responsible for the day-to-day operation of such political party at

the national level, as determined by the Commission.” 2 U.S.C. § 431(14). RNC is a “political

committee[] established and maintained by a national political party” under 2 U.S.C.

§ 441a(a)(1)(B), i.e., it is a national-party committee. At the authorization of Chairman Priebus,

RNC will (a) establish an NCA, (b) solicit unlimited contributions for, and direct such contributions to, the NCA, and (c) make only independent expenditures regarding federal candidates and

other independent communications that refer to federal candidates from the funds contributed to

the NCA. Without the relief requested herein, RNC will not do so.

12. Plaintiff Reince Priebus is the RNC Chairman and, in that capacity, he is “chief executive

officer of the Republican National Committee.” The Rules of the Republican Party at Rule No.

5(a)(1). He is eligible to vote in an election for the office of the President of the United States. 5

He intends to (a) establish an NCA in RNC, (b) authorize RNC’s NCA to make only independent

expenditures regarding federal candidates and other independent communications that refer to

federal candidates, and (c) solicit unlimited contributions for, and direct such contributions to,

RNC’s NCA, if it were legal to do so. Without the relief requested herein, he will not do so.

13. Plaintiff Republican Party of Louisiana (“LAGOP”) is a “State committee,” i.e., “the orAvailable at http://www.gop.com/wp-content/uploads/2014/03/Rules-of-the-Republican- 5

Party.pdf.

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Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 5 of 22
ganization which, by virtue of the bylaws of a political party, is responsible for the day-to-day

operation of such political party at the State level, as determined by the Commission.” 2 U.S.C.

§ 431(15). LAGOP is a “political committee established and maintained by a State committee

established and maintained by a State committee of a political party” under 2 U.S.C.

§ 441a(a)(1)(D), i.e., it is a state-party committee. At the authorization of LAGOP Chairman

Roger Villere, LAGOP intends to (a) establish an NCA, (b) solicit unlimited contributions to the

NCA, and (c) make only independent expenditures regarding federal candidates and other independent communications that refer to federal candidates from the funds contributed to the NCA,

when lawful to do so. Without the requested relief, LAGOP will not do so. In addition, LAGOP

intends to use Louisiana state-regulated funds for independent federal election activity, when

lawful to do so. Without the requested relief, LAGOP will not do so.

14. Plaintiff Roger Villere, Jr. is LAGOP Chairman. He is eligible to vote in an election for

the office of the President of the United States. He intends to (a) authorize LAGOP to establish

an NCA, (b) solicit unlimited contributions to the NCA, and (c) make only independent expenditures regarding federal candidates and other independent communications that refer to federal

candidates from the funds contributed to the NCA, when lawful to do so. Without the requested

relief, he will not authorize LAGOP to do so. In addition, he intends to authorize LAGOP to use

Louisiana state-regulated funds for independent federal election activity, when lawful to do so.

Without the requested relief, he will not authorize LAGOP to do so.

15. Jefferson Parish Republican Parish Executive Committee (“JPGOP”) is a “local committee of a political party,” 2 U.S.C. § 441i(b)(1), i.e., a local committee of LAGOP. It intends to

use Louisiana state-regulated funds for independent federal election activity, when lawful to do

so. Without the requested relief, JPGOP will not do so.

Verified Complaint 6

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16. Orleans Parish Republican Executive Committee (“OPGOP”) is a “local committee of a

political party,” 2 U.S.C. § 441i(b)(1), i.e., a local committee of LAGOP. It intends to use Louisiana state-regulated funds for independent federal election activity, when lawful to do so. Without

the requested relief, OPGOP will not do so.

17. FEC is the government agency with enforcement authority over BCRA and the Federal

Election Campaign Act of 1971(“FECA”), as amended, 2 U.S.C. § 431 et seq.

Legal Context

IE-PACs & NCAs

18. In SpeechNow.org v. FEC, 599 F.3d 686 (D.C. Cir. 2010) (en-banc) (“SpeechNow”), the

D.C. Circuit held that government may not limit the amount of contributions to an independentexpenditure-only political committee (“IE-PAC”) because there is no justifying interest:

[B]ecause Citizens United holds that independent expenditures do not corrupt or give the

appearance of corruption as a matter of law, then the government can have no anti-corruption interest in limiting contributions to independent expenditure-only organizations. No

matter which standard of review governs contribution limits, the limits on contributions to

SpeechNow cannot stand.

Id. at 696 (citing Citizens United, 558 U.S. 310).6

19. In Advisory Opinion 2010-09 (Club for Growth), FEC decided that an IE-PAC may re- 7

ceive contributions in unlimited amounts from individuals after notifying the FEC of its intent in

the following words:

This committee intends to make independent expenditures, and consistent with the U.S.

Court of Appeals for the District of Columbia Circuit decision in SpeechNow v. FEC, it

therefore intends to raise funds in unlimited amounts. This committee will not use those

funds to make contributions, whether direct, in-kind, or via coordinated communications,

to federal candidates or committees.

 Here, “standard of review” should read “scrutiny level.” 6

Available at http://saos.fec.gov/aodocs/AO%202010-09.pdf. 7

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Id. at Attachment A.

20. In Advisory Opinion 2010-11 (Commonsense Ten), FEC decided that an IE-PAC may 8

also receive unlimited contributions from political committees, corporations, and unions to fund

independent expenditures.

21. In Carey v. FEC, 791 F.Supp.2d 121 (D.D.C. 2011), this Court granted a preliminary injunction for the National Defense PAC, which sought to operate as a hybrid-PAC—with one account for making contributions (subject to the base limits on contributions to PACs) and another

account for making independent expenditures (to receive unlimited contributions). FEC then

agreed to a stipulated order and consent judgment allowing the PAC to operate as a hybrid-PAC,

with its non-contribution account able to receive unlimited contributions. See

http://www.fec.gov/law/litigation/carey.shtml (describing litigation and consent judgment with

links to case documents).

22. FEC then issued the FEC Statement on Carey v. FEC: Reporting Guidance for Political

Committees that Maintain a Non-Contribution Account (“NCA Guidance”), which declared the 9

scope of its non-enforcement regarding NCAs as follows:

The Commission will no longer enforce 2 U.S.C. §§441a(a)(1)(C) and 441a(a)(3), as [10]

well as any implementing regulations, against any nonconnected political committee with

regard to contributions from individuals, political committees, corporations, and labor organizations, as long as (1) the committee deposits the contributions into a separate bank account for the purpose of financing independent expenditures, other advertisements that refer to a Federal candidate, and generic voter drives (the “Non-Contribution Account”), (2)

the Non-Contribution Account remains segregated from any accounts that receive sourcerestricted and amount-limited contributions for the purpose of making contributions to candidates, and (3) each account pays a percentage of administrative expenses that closely corAvailable at http://saos.fec.gov/aodocs/AO%202010-11.pdf. 8

 Available at http://www.fec.gov/press/press2011/20111006postcarey.shtml. 9

 Section 441a(a)(1) imposes base limits on contributions. Section 441a(a)(3) imposed ag10

gregate limits held unconstitutional in McCutcheon v. FEC, 134 S.Ct. 1434 (2014).

Verified Complaint 8

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 8 of 22
responds to the percentage of activity for that account.

Id. (emphasis added).

23. In McConnell v. FEC, 540 U.S. 93 (2003), the Supreme Court held that political-party committees also could not be forced to choose between making independent expenditures and contributions to candidates (i.e., coordinated expenditures), id. at 213-19. Thus, political-party committees

are also political committees that may have separate accounts for making independent expenditures

and contributions to candidates.

Other Facts

RNC and LAGOP NCAs

24. RNC and LAGOP want to create their own NCAs, as other political committees may do,

on the authorization of Plaintiff Priebus for RNC and Plaintiff Villere for LAGOP, subject to all

applicable federal laws and regulations and pursuant to the standards of Colorado-I, 518 U.S.

604, regarding political-party committees’ independent expenditures.

25. FEC’s NCA Guidance recognizes the right of nonconnected political committees to form

NCAs, but “nonconnected political committee” is defined to exclude party committees: “A

nonconnected committee is a political committee that is not a party committee, an authorized

committee of a candidate or a separate segregated fund established by a corporation of labor organization. 100.5(a) and 106.6(a).” FEC, Federal Election Commission Campaign Guide:

Nonconnected Committees at 1 (May 2008). Thus, FEC’s statement of non-enforcement for 11

NCAs does not extend to RNC’s or LAGOP’s intended NCA.

26. RNC and LAGOP regularly receive contributions from individuals and will continue to

do so. RNC and LAGOP regularly make independent expenditures regarding federal candidates

Available at http://www.fec.gov/pdf/nongui.pdf. 11

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and other independent communications that refer to federal candidates and will continue to do so.

RNC’s independent-expenditure activity currently must use funds subject to RNC’s base contribution limit. See 2 U.S.C. § 441a(a)(1)(B) (currently $32,400/year). LAGOP’s independent-expenditure activity currently must use funds subject to LAGOP’s base contribution limit. See 2

U.S.C. § 441a(a)(1)(D) (currently $10,000/year, with limit shared between state, district, and local parties within a state). RNC and LAGOP reasonably believe that some of their contributors

will contribute to an RNC NCA and an LAGOP NCA, in amounts above the current contribution

limits, if the judicial relief sought herein is granted.

27. Plaintiffs Priebus and RNC want to form RNC’s NCA as soon as possible and begin soliciting and raising funds without contribution limits in the NCA for making independent expenditures and independent communications naming federal candidates. Priebus and RNC intend in

2014 to use RNC’s NCA to conduct this independent activity in select U.S. Senate and House

races. They intend in 2016 to conduct this independent activity in select U.S. Senate and House

races as well to support the Republican nominee for President. They intend to do materially similar independent activity in the future.

28. Plaintiffs Villere and LAGOP want to form LAGOP’s NCA as soon as possible and begin

soliciting and raising funds without contribution limits in the NCA for making independent expenditures and independent communications naming federal candidates. In 2014, Villere and

LAGOP intend to use LAGOP’s NCA to conduct this independent activity to support the Republican opponent of U.S. Senator Mary Landrieu, who is up for election in November 2014, as well

as selected Republican candidates for Congress. They intend to do materially similar independent

activity in the future.

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LAGOP’s, JPGOP’s, and OPGOP’s Funding of Independent Federal Election Activity

29. LAGOP, JPGOP, and OPGOP want to use Louisiana state-regulated funds for independent federal election activity, upon authorization and when legal to do so. However, these plaintiffs are prohibited by 2 U.S.C. § 441i(b) from doing so and will not do so unless they receive the

requested relief herein.

30. LAGOP, JPGOP, and OPGOP want to use Louisiana state-regulated funds for independent federal election activity in connection with the 2014, 2015, 2016, and 2017 elections. An example of the sort of independent federal election activity they wish to do without having to use

federal funds is LAGOP’s plans to make independent communications to support the Republican

opponent of U.S. Senator Mary Landrieu, who is up for election in November 2014, that criticize

her support for certain government policies, such as Obamacare, without expressly advocating

her defeat. These independent communications would be federal election activity because each

would be

a public communication that refers to a clearly identified candidate for Federal office (regardless of whether a candidate for State or local office is also mentioned or identified) and

that promotes or supports a candidate for that office, or attacks or opposes a candidate for

that office (regardless of whether the communication expressly advocates a vote for or

against a candidate).

2 U.S.C. § 431(20)(A)(iv). Absent the relief sought here, LAGOP would be limited to using federal funds for its planned independent communications. Contributors to LAGOP, JPGOP, and

OPGOP are limited by a federal base limit of $10,000/year, which they must share, in raising federal funds. 2 U.S.C. § 441a(a)(1)(D).

31. In addition, if they receive the requested judicial relief, LAGOP, JPGOP, and OPGOP

also intend to use non-federal funds to conduct other federal election activity, such as voter registration, voter identification, get-out-the-vote, and generic campaign activities that would fall

Verified Complaint 11

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within the federal-election-activity definition, in connection with the 2014, 2015, 2016, and 2017

elections. They intend to do materially similar activity in the future.

Future Plans and Ongoing and Irreparable Harm

32. In the future, all Plaintiffs intend to take actions materially similar to those that they desire and intend to take here, if not limited or prohibited by the challenged laws. Given the recurring election-related context, the usual length of time for litigation such as this to be finally resolved, and the ongoing restrictions imposed by challenged laws, there is a strong likelihood that

situations similar to those described here will recur without opportunity for full litigation. Thus,

even if this case is not fully litigated before 2014, 2015, 2016, and 2017 elections, this case will

not be moot because it will be capable of repetition yet evading review. See, e.g., FEC v. Wisconsin Right to Life, 551 U.S. 449, 461-63 (2007) (“WRTL-II”) (Roberts, C.J., joined by Alito, J.)

(controlling opinion, Marks, 430 U.S. at 193).

33. Plaintiffs will face a credible threat of prosecution if they proceed with their intended activities without the requested relief.

34. If Plaintiffs do not obtain the requested relief, they will not proceed with their intended

activities. In such an event, they will be deprived of their constitutional rights under the First

Amendment to the United State Constitution and will suffer irreparable harm. There is no adequate remedy at law.

Count 1

Provisions Preventing Party-Committee NCAs

35. Plaintiffs reallege and incorporate by reference all of the allegations in all of the preceding paragraphs.

36. Plaintiffs RNC and LAGOP are federal political-party committees that want to form

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NCAs, as other federal political committees may do.

37. As indicated in NCA Guidance, FEC has recognized only the right of “nonconnected political committees” to form NCAs, which excludes political-party committees.

38. Therefore, plaintiffs are prohibited from operating an NCA by the non-federal-funds prohibitions at 2 U.S.C. § 441i (titled “Soft money of political parties”).

39. Plaintiffs challenge the non-federal-funds prohibitions at 2 U.S.C. § 441i(a)-(c) as unconstitutional under the First Amendment as applied to plaintiffs’ intended NCAs.

40. In the alternative, the non-federal-funds prohibitions at 2 U.S.C. § 441i(a)-(c) are unconstitutional facially. McConnell v. FEC, 540 U.S. 93 (2003), upheld the non-federal-fund prohibitions on their face despite the fact that the McConnell defendants, including FEC, “ha[d] identified not a single discrete instance of quid pro quo corruption attributable to the donation of

non-federal funds to the national party committees.” McConnell v. FEC, 251 F.Supp.2d 176, 395

(D.D.C. 2003) (opinion of Henderson, J.). Accord McCutcheon, 134 S.Ct. at 1469-70 (Breyer, J.,

joined by Ginsburg, Sotomayor & Kagan, dissenting) (quoting and citing McConnell, 251

F.Supp.2d at 395) (opinion of Henderson, J.)). However the U.S. Supreme Court, in Citizens

United, 558 U.S. at 359-60, and McCutcheon, 134 S.Ct. at 1450-51 (controlling opinion), requires evidence of quid-pro-quo corruption to uphold such restrictions. The non-federal-funds

prohibitions are unconstitutional on their face. 

41. Furthermore, plaintiffs’ intended NCAs would be subject to the base limits on contributions to national-party and state-party committees. 2 U.S.C. § 441a(a)(1)(B), (D).

42. However, base contribution limits have already been held unconstitutional as applied to

IE-PACs and NCAs. Since they serve no cognizable governmental interest, see, e.g., SpeechNow,

599 F.3d at 689, the base limits on contributions to national- and state-party committees cannot

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constitutionally be applied to their intended NCAs. Therefore, plaintiffs challenge the base contribution limits, 2 U.S.C. § 441a(a)(1)(B), (D), as unconstitutional under the First Amendment as

applied to their intended NCAs.12

Count 2

Provision Preventing National Party Officers/Agents from

Soliciting Non-Federal Funds for Party-Committee NCAs

43. Plaintiffs reallege and incorporate by reference all of the allegations in all of the preceding paragraphs.

44. Plaintiff Priebus wants to solicit unlimited contributions for, or direct contributions to,

RNC’s intended NCA, but he is prohibited by the non-federal-funds ban at 2 U.S.C. § 441i(a),

which mandates that RNC, its “officers or agents,” and created entities “may not solicit, receive,

or direct” non-federal funds. RNC wants its Chairman and other RNC officers and agents to be

able to do so.

45. FEC construed the non-federal-funds ban on solicitation/direction by national-party committees, officers, and agents, 2 U.S.C. § 441i(a), to permit national-party committees’ offi-

 Though other NCAs may receive corporate and union contributions, see, e.g., NCA Guid- 12

ance, plaintiffs do not presently seek that relief for their NCAs. They do not challenge the ban on

corporate and union contributions, 2 U.S.C. § 441b, because this is a BCRA challenge under

which the non-BCRA provision at § 441b may not be challenged. See BCRA § 403(a) (special

proceedings for a “challenge [to] the constitutionality of any provision of this Act or any amendment made by this Act” (emphasis added)).

Rather, plaintiffs challenge only BCRA provisions/amendments (BCRA §§ 101 (“Soft

Money of Political Parties”), 102 (“Increased Contribution Limits for State Committees of Political Parties”), and 307 (“Modification of Contribution Limits”)) as permitted by BCRA’s special

“judicial review” procedures. See McConnell, 540 U.S. at 132 (case brought under BCRA § 403),

229 (“the Court has jurisdiction to hear a challenge to § 307”).

As a result, if plaintiffs prevail in this case, their NCAs will be unable to receive corporate or

union contributions. Upon completion of this case, Plaintiffs will consider whether to seek authority for their NCAs to receive all of the same contributions that other NCAs may accept in a

separate and future legal action, but that is beyond the scope of this action.

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cers/agents to solicit for, or direct to, an IE-PAC only contributions up to the base contribution

limit applicable to multicandidate PACs (currently $5000/year), even though this base contribution limit is unconstitutional as applied to IE-PACs. See AO 2011-12 (Majority PAC). So if RNC

may establish an NCA, Plaintiff Priebus would be allowed to solicit contributions only up to the

base limit for a national-party committee (currently $32,400/year) for RNC’s NCA, even though

the base contribution limit is unconstitutional as applied to RNC’s NCA.

46. The solicitation/direction provision at 2 U.S.C. § 441i(a) is unconstitutional under the

First Amendment guarantees of free speech and association as applied to national-party officers/agents soliciting unlimited contributions for, or directing unlimited contributions to, a

national-party committee’s NCA.

47. In the alternative, the non-federal-funds prohibitions at 2 U.S.C. § 441i(a) are unconstitutional facially. McConnell, 540 U.S. 93, upheld the non-federal-fund prohibitions on their face

despite the fact that the McConnell defendants, including FEC, “ha[d] identified not a single discrete instance of quid pro quo corruption attributable to the donation of non-federal funds to the

national party committees.” McConnell, 251 F.Supp.2d at 395 (opinion of Henderson, J.). Accord

McCutcheon, 134 S.Ct. at 1469-70 (Breyer, J., joined by Ginsburg, Sotomayor & Kagan, dissenting) (quoting and citing McConnell, 251 F.Supp.2d at 395) (opinion of Henderson, J.)). However

the U.S. Supreme Court, in Citizens United, 558 U.S. at 359-60, and McCutcheon, 134 S.Ct. at

1450-51 (controlling opinion), requires evidence of quid-pro-quo corruption to uphold such restrictions. The non-federal-funds prohibitions are unconstitutional on their face.

Verified Complaint 15

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Count 3

Provisions Prohibiting Non-Federal Funds for

Independent Federal Election Activity

48. Plaintiffs reallege and incorporate by reference all of the allegations in all of the preceding paragraphs.

49. LAGOP, JPGOP, and OPGOP want to engage in independent federal election activity

using Louisiana state-regulated funds.

50. However, the non-federal-funds prohibition at 2 U.S.C. § 441i(b) would limit them to

using federal funds for their intended independent federal election activity. Section 441i(b) requires that funds “expended or disbursed” for “federal election activity” “be made from funds

subject to the limitations, prohibitions, and reporting requirements of this Act.” Louisiana stateregulated funds are not subject to “the limitations, prohibitions, and reporting requirements” of

FECA, as amended by BCRA.

51. “Federal election activity” includes:

(i) voter registration activity during the period that begins on the date that is 120 days before the date a regularly scheduled Federal election is held and ends on the date of the

election;

(ii) voter identification, get-out-the-vote activity, or generic campaign activity conducted

in connection with an election in which a candidate for Federal office appears on the ballot (regardless of whether a candidate for State or local office also appears on the ballot);

(iii) a public communication that refers to a clearly identified candidate for Federal office

(regardless of whether a candidate for State or local office is also mentioned or identified)

and that promotes or supports a candidate for that office, or attacks or opposed a candidate

for that office (regardless of whether the communication expressly advocates a vote for or

against a candidate); or

(iv) services provided during any month by an employee of a State, district, or local committee of a political party who spends more that 25 percent of that individual’s compensated time during that month on activities in connection with a Federal election.

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Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 16 of 22
2 U.S.C. § 431(20)(A).

52. The non-federal-funds prohibition on federal election activity, 2 U.S.C. § 441i(b), therefore, is unconstitutional under the First Amendment guarantees of free speech and association as

applied to independent federal election activity.

53. Moreover, 2 U.S.C. § 441i(c) would require plaintiffs to use federal funds for fundraising

for federal election activities, which is also unconstitutional under the First Amendment as applied to independent federal election activity.

54. In the alternative, the non-federal-funds prohibitions at 2 U.S.C. § 441i(b)-(c) are unconstitutional facially. McConnell, 540 U.S. 93, upheld the non-federal-fund prohibitions on their

face despite the fact that the McConnell defendants, including FEC, “ha[d] identified not a single

discrete instance of quid pro quo corruption attributable to the donation of non-federal funds to

the national party committees.” McConnell, 251 F.Supp.2d at 395 (opinion of Henderson, J.).

Accord McCutcheon, 134 S.Ct. at 1469-70 (Breyer, J., joined by Ginsburg, Sotomayor & Kagan,

dissenting) (quoting and citing McConnell, 251 F.Supp.2d at 395 (opinion of Henderson, J.)).

However the U.S. Supreme Court, in Citizens United, 558 U.S. at 359-60, and McCutcheon, 134

S.Ct. at 1450-51 (controlling opinion), requires evidence of quid-pro-quo corruption to uphold

such restrictions. The non-federal-funds prohibitions are unconstitutional on their face.

Prayer for Relief

Wherefore, Plaintiffs pray for the following relief:

1. Convening of a three-judge court to consider this “action . . . brought for declaratory or

injunctive relief to challenge the constitutionality of any provision of [BCRA] or any amendment

made by [BCRA],” BCRA § 403(a), 116 Stat. at 113-14, under BCRA § 403, Local Civil Rule

9.1, and pertinent law, as soon as practical.

Verified Complaint 17

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 17 of 22
2. “[A]dvance[ment] on the docket and . . . expedit[ion] to the greatest possible extent the

disposition of this action . . . .” BCRA § 403(a)(4) and (d)(2).

3. As requested in Count 1, declaratory judgments that

• 2 U.S.C. § 441i(a)-(c) (non-federal-funds prohibitions) is unconstitutional under the

First Amendment as applied to plaintiffs’ intended NCAs;

• in the alternative, § 441i(a)-(c) is unconstitutional facially; and

• the base contribution limits, 2 U.S.C. § 441a(a)(1)(B), (D), are unconstitutional under

the First Amendment as applied to plaintiffs’ intended NCAs;

4. Preliminary and permanent injunctions enjoining FEC from enforcing the foregoing challenged provisions.

5. As requested in Count 2, a declaratory judgment that 2 U.S.C. § 441i(a) is unconstitutional

as applied to national-party committee officers/agents soliciting unlimited contributions for, or

directing contributions to, a national-party committee’s NCA;

6. Preliminary and permanent injunctions enjoining FEC from enforcing § 441i(a) as applied

to national-party committee officers/agents soliciting unlimited contributions for, or directing

contributions to, a national-party committee’s NCA;

7. In the alternative, a declaratory judgment that the non-federal-funds prohibitions at

§ 441i(a) are facially unconstitutional, along with preliminary and permanent injunctions against

enforcement of said provision.

8. As requested in Count 3, a declaratory judgment that 2 U.S.C. § 441i(b)-(c) is unconstitutional as applied to independent federal election activity by state- and local-party committees;

9. Preliminary and permanent injunctions enjoining FEC from enforcing § 441i(b)-(c) as applied to independent federal election activity by state- and local-party committees;

Verified Complaint 18

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 18 of 22
10. In the alternative, a declaratory judgment that the non-federal-funds prohibitions at

§ 441i(b)-(c) are facially unconstitutional, along with preliminary and permanent injunctions

against enforcement of these provisions.

11. Costs and attorneys fees pursuant to any applicable statute or authority.

12. Any other relief that this Court in its discretion deems just and appropriate.

Respectfully submitted,

 /s/ James Bopp, Jr.

James Bopp, Jr., DC Bar #CO 0041

jboppjr@aol.com

Richard E. Coleson*

rcoleson@bopplaw.com

Randy Elf*

relf@bopplaw.com

THE BOPP LAW FIRM, PC

1 South Sixth Street

Terre Haute, IN 47807-3510

812/232-2434 telephone

812/235-3685 facsimile

Counsel for Plaintiffs

*Pro Hac Vice Application To Be Filed

Verified Complaint

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 19 of 22
Verification 

I, Reince Priebus, declare as follows: 

1. I am a Plaintiff in the present case and a citizen of the United States of America. I am 

eligible to vote in an election for the office of the President of the United States. I am Chairman 

of the Republican National Committee (RNC). 

2. I have personal knowledge of mysclf, my activities, and my intentions, including those 

set out in the foregoing Verified Complaint/or Deciara/Oly and Injunctive Relief, and if ealled on 

to testify I would competently testify as to the matters statcd hcrein. 

3.1 have personal knowledge ofRNC, its activities, and its intentions, including those sct 

out in the foregoing Verified Complaint jiJr DeclaratOlY and Injunctive Reli~f, and if called on to 

testify I would competently testify as to the matters stated herein. 

4. I verify under penalty of pe\jury under the laws of the United States of America that the 

factual statements in this Complaint concerning myself, my activities, and my intentions are true 

and eorrcct, as are the factual statements concerning RNC, its activities, and its intentions. 28 

U.S.C. § 1746. III )'1t 

Executed onl'l't ~ , ,2014. 

• 

. Priebus 

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 20 of 22
Verification

I, Roger Villere, Jr., declare as follows:

I. I am a Plaintiff in the present case, a citizen ofthe United States ofAmerica, and a

resident of the State of Louisiana. I am eligible to vote in an election for the officc ofthe

President of the United States. I am Chairman ofthe Republican Party of Louisiana ("LAGOP").

2. I havc personal knowledge of myself, my activities, and my intentions, including those

set out in the foregoing Verified Complaintfor Declaratory and Injunctive Relief; and if called on

to testify I would competently testify as to the matters stated herein.

3. I have personal knowledge of LAGOP, the Jefferson Parish Republican Parish

Executive Committee ("JPGOP"), and the Orleans Parish Republican Executive Committee

("OPGOP"), their activities, and their intentions, including those set out in the foregoing Verified

Complaintfor DeclaratOlY and Injunctive Relief, and if called on to testify I would competently

testify as to the matters stated herein.

4. I verify under penalty of perjury under the laws of the United States ofAmerica that the

factual statements in this Complaint concerning myself, my activities, and my intentions arc true

and correct, as are the factual statements concerning LAGOP, JPGOP, OPGOP, their activities,

and their intentions. 28 U.S.c. § 1746.

~.;=;:

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 21 of 22
Certificate of Service

I hereby certify that the foregoing complaint will be served as soon as the summons is available on the following persons by certified mail, return receipt requested, and that a courtesy copy

will be emailed to Kevin Deeley, FEC’s Acting Associate General Counsel for Litigation, at

kdeeley@fec.gov:

General Counsel

FEDERAL ELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

(202) 694-1650

Civil Process Clerk

UNITED STATES ATTORNEY’S OFFICE

501 Third Street, NW

Washington, DC 20530

Eric H. Holder, U.S. Attorney General

U.S. DEPARTMENT OF JUSTICE

950 Pennsylvania Ave. NW

Washington, DC 20530.

I further certify that on the same date a copy of the complaint will be provided by the same

means “to the Clerk of the House of Representatives and the Secretary of the Senate” as required

under § 403(a)(2) of the Bipartisan Campaign Reform Act of 2002, 116 Stat. 114, at the following addresses:

Clerk of the House of Representatives

U.S. HOUSE OF REPRESENTATIVES

U.S. Capitol, Room H154

Washington, DC 20515-6601

Secretary of the Senate

UNITED STATES SENATE

Washington, DC 20510-6601.

 /s/ James Bopp, Jr.

James Bopp, Jr., DC Bar #CO 0041

Verified Complaint

Case 1:14-cv-00853 Document 1 Filed 05/23/14 Page 22 of 22
CIVIL COVER SHEET

JS-44

(Rev.1/05 DC)

I (a) PLAINTIFFS

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF

 (EXCEPT IN U.S. PLAINTIFF CASES)

DEFENDANTS

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT 

(IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF

LAND INVOLVED

(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN)

II. BASIS OF JURISDICTION

(PLACE AN x IN ONE BOX ONLY)

 1 U.S. Government 3 Federal Question

 Plaintiff (U.S. Government Not a Party) 

 2 U.S. Government 4 Diversity

 Defendant (Indicate Citizenship of 

 Parties in item III)

III CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX 

FOR PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!

 PTF DFT PTF DFT

Citizen of this State 1 1 Incorporated or Principal Place 4 4

 of Business in This State

Citizen of Another State 2 2 Incorporated and Principal Place 5 5

 of Business in Another State

Citizen or Subject of a 3 3

Foreign Country Foreign Nation 6 6

IV. CASE ASSIGNMENT AND NATURE OF SUIT

(Place a X in one category, A-N, that best represents your cause of action and one in a corresponding Nature of Suit)

 A. Antitrust

 410 Antitrust

 B. Personal Injury/

 Malpractice

 310 Airplane

 315 Airplane Product Liability

 320 Assault, Libel & Slander

 330 Federal Employers Liability

 340 Marine

 345 Marine Product Liability

 350 Motor Vehicle

 355 Motor Vehicle Product Liability

 360 Other Personal Injury

 362 Medical Malpractice

 365 Product Liability

 368 Asbestos Product Liability 

 C. Administrative Agency

 Review

 151 Medicare Act

Social Security:

 861 HIA ((1395ff)

 862 Black Lung (923)

 863 DIWC/DIWW (405(g)

 864 SSID Title XVI

 865 RSI (405(g)

 Other Statutes

 891 Agricultural Acts

 892 Economic Stabilization Act

 893 Environmental Matters

 894 Energy Allocation Act

 890 Other Statutory Actions (If 

 Administrative Agency is Involved)

 D. Temporary Restraining

 Order/Preliminary

 Injunction

Any nature of suit from any category may

be selected for this category of case

assignment.

*(If Antitrust, then A governs)*

 E. General Civil (Other) OR F. Pro Se General Civil

Real Property

 210 Land Condemnation

 220 Foreclosure

 230 Rent, Lease & Ejectment

 240 Torts to Land

 245 Tort Product Liability

 290 All Other Real Property

Personal Property

 370 Other Fraud

 371 Truth in Lending

 380 Other Personal Property Damage

 385 Property Damage Product Liability

Bankruptcy

 422 Appeal 28 USC 158

 423 Withdrawal 28 USC 157

Prisoner Petitions

 535 Death Penalty

 540 Mandamus & Other

 550 Civil Rights

 555 Prison Condition

Property Rights

 820 Copyrights

 830 Patent

 840 Trademark

Federal Tax Suits

 870 Taxes (US plaintiff or 

 defendant

 871 IRS-Third Party 26 

 USC 7609

Forfeiture/Penalty

 610 Agriculture

 620 Other Food &Drug

 625 Drug Related Seizure 

 of Property 21 USC 881

 630 Liquor Laws

640 RR & Truck

 650 Airline Regs

 660 Occupational 

 Safety/Health

 690 Other

Other Statutes

 400 State Reapportionment

 430 Banks & Banking

 450 Commerce/ICC 

 Rates/etc.

 460 Deportation

 470 Racketeer Influenced & 

 Corrupt Organizations

 480 Consumer Credit

 490 Cable/Satellite TV

 810 Selective Service

 850 Securities/Commodities/

 Exchange

 875 Customer Challenge 12 USC 

 3410

 900 Appeal of fee determination

 under equal access to Justice

 950 Constitutionality of State

 Statutes

 890 Other Statutory Actions (if 

 not administrative agency 

 review or Privacy Act

Republican National Committee, et al. Federal Election Commission

11001

James Bopp, Jr.; Richard E. Coleson; et al.

The Bopp Law Firm, P.C.

1 South Sixth Street

Terre Haute, Ind. 47807

Office of the General Counsel

Federal Election Commission

999 E Street, N. W.

Washington, D. C. 20463

Case 1:14-cv-00853 Document 1-1 Filed 05/23/14 Page 1 of 2
G. Habeas Corpus/

2255

 530 Habeas Corpus-General

510 Motion/Vacate Sentence

H. Employment

Discrimination

 442 Civil Rights-Employment

 (criteria: race, gender/sex,

 national origin,

 discrimination, disability

 age, religion, retaliation)

*(If pro se, select this deck)*

I. FOIA/PRIVACY 

ACT

 895 Freedom of Information Act

 890 Other Statutory Actions

 (if Privacy Act)

*(If pro se, select this deck)*

J. Student Loan

 152 Recovery of Defaulted 

 Student Loans 

 (excluding veterans)

K. Labor/ERISA

(non-employment)

 710 Fair Labor Standards Act

 720 Labor/Mgmt. Relations

 730 Labor/Mgmt. Reporting &

 Disclosure Act

 740 Labor Railway Act

 790 Other Labor Litigation

 791 Empl. Ret. Inc. Security Act

L. Other Civil Rights

 (non-employment)

 441 Voting (if not Voting Rights

 Act)

 443 Housing/Accommodations

 444 Welfare

 440 Other Civil Rights

 445 American w/Disabilities-

 Employment

 446 Americans w/Disabilities- 

 Other

M. Contract

 110 Insurance

 120 Marine

 130 Miller Act

 140 Negotiable Instrument

 150 Recovery of Overpayment &

 Enforcement of Judgment

 153 Recovery of Overpayment of

 Veteran’s Benefits

 160 Stockholder’s Suits

 190 Other Contracts

 195 Contract Product Liability

 196 Franchise

N. Three-Judge Court

 441 Civil Rights-Voting 

 (if Voting Rights Act)

V. ORIGIN

 1 Original 2 Removed 3 Remanded from 4 Reinstated 5 Transferred from 6 Multi district 7 Appeal to

 Proceeding from State Appellate Court or Reopened another district Litigation District Judge

 Court (specify) from Mag. Judge 

 VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

VII. REQUESTED IN CHECK IF THIS IS A CLASS DEMAND $ Check YES only if demanded in complaint

COMPLAINT ACTION UNDER F.R.C.P. 23 JURY DEMAND: YES NO

VIII. RELATED CASE(S) (See instruction) YES NO If yes, please complete related case form.

IF ANY

DATE SIGNATURE OF ATTORNEY OF RECORD

INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44

Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleadings or other papers as required by

law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of

Court for the purpose of initiating the civil docket sheet. Consequently a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed. Listed below are tips

for completing the civil cover sheet. These tips coincide with the Roman Numerals on the Cover Sheet.

I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff is resident of

Washington, D.C.; 88888 if plaintiff is resident of the United States but not of Washington, D.C., and 99999 if plaintiff is outside the United States.

III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction under Section

II.

IV. CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best represents the

primary cause of action found in your complaint. You may select only one category. You must also select one corresponding nature of suit found under

the category of case. 

VI. CAUSE OF ACTION: Cite the US Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII. RELATED CASES, IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from the Clerk’s

Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.

/s/ James Bopp, Jr.

✘

Challenge to constitutionality of multiple provisions of the Federal Election Campaign Act, 2 U.S.C. 431 et seq.

0

May 23, 2014

✘

✘

Case 1:14-cv-00853 Document 1-1 Filed 05/23/14 Page 2 of 2
28 USC 1608 Summons

12/11

 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA

 )

Plaintiff )

)

v. ) Civil Action No.

)

 )

Defendant )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 60 days after service of this summons on you (not counting the day you received it) you must

serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of

Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and

address are:

If you fail to respond, judgment by default may be entered against you for the relief demanded in the

complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date: 

Signature of Clerk or Deputy Clerk

Republican National Committee et al.

Federal Election Commission

Eric H. Holder, U.S. Attorney General

U.S. Department of Justice

950 Pennsylvania Ave. NW

Washington, DC 20530

James Bopp, Jr.

The Bopp Law Firm, PC

1 S. Sixth St.

Terre Haute, Ind. 47807-3510

Case 1:14-cv-00853 Document 1-3 Filed 05/23/14 Page 1 of 2
	







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Case 1:14-cv-00853 Document 1-3 Filed 05/23/14 Page 2 of 2
28 USC 1608 Summons

12/11

 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA

 )

Plaintiff )

)

v. ) Civil Action No.

)

 )

Defendant )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 60 days after service of this summons on you (not counting the day you received it) you must

serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of

Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and

address are:

If you fail to respond, judgment by default may be entered against you for the relief demanded in the

complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date: 

Signature of Clerk or Deputy Clerk

Republican National Committee et al.

Federal Election Commission

Civil Process Clerk

United States Attorney's Office

501 Third Street, NW

Washington, DC 20530

James Bopp, Jr.

The Bopp Law Firm, PC

1 S. Sixth St.

Terre Haute, IN 47807-3510

Case 1:14-cv-00853 Document 1-4 Filed 05/23/14 Page 1 of 2
	







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Case 1:14-cv-00853 Document 1-4 Filed 05/23/14 Page 2 of 2
28 USC 1608 Summons

12/11

 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA

 )

Plaintiff )

)

v. ) Civil Action No.

)

 )

Defendant )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 60 days after service of this summons on you (not counting the day you received it) you must

serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of

Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and

address are:

If you fail to respond, judgment by default may be entered against you for the relief demanded in the

complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date: 

Signature of Clerk or Deputy Clerk

Republican National Committee et al.

Federal Election Commission

Federal Election Commission

999 E Street, NW

Washington, DC 20436

James Bopp, Jr.

The Bopp Law Firm, PC

1 S. Sixth St.

Terre Haute, Ind. 47807-3510

Case 1:14-cv-00853 Document 1-2 Filed 05/23/14 Page 1 of 2
	







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Case 1:14-cv-00853 Document 1-2 Filed 05/23/14 Page 2 of 2