17 Vt. Stat. Ann. § 2805

Law changed since Vermont repealed § 2805 on January 23, 2014, through 2013, No. 90 (Adj. Sess.), § 2; new contribution limits in § 2941 took effect January 1, 2015.

Section 2805(c)'s 25-percent cap on out-of-state campaign contributions violates the First Amendment.

Landell v. Sorrell · filed 2000-08-28(c)

Act 64’s 25% limit on out-of-state funds, Vt.Stat.Ann. tit. 17, § 2805(c), violates candidates’ and contributors’ First Amendment rights of free speech and association, and is therefore unconstitutional.

Law changed since Same change as noted above.

Section 2805(c)'s limits on contributions from non-Vermont residents and organizations are unconstitutional, and enforcement of that provision is enjoined.

Landell v. Sorrell · filed 2002-08-07(c)

from non-Vermont residents and organizations (§ 2805(c)) are unconstitutional and we uphold its injunction against enforcement of that provision.

Law changed since Randall v. Sorrell, 548 U.S. 230 (2006), reversed this approval of § 2805(a) and (b) without disturbing the subsection (c) ruling; Vermont then repealed § 2805 on January 23, 2014, and new limits in § 2941 took effect January 1, 2015.

Section 2805 generally permits contribution limits for candidates, PACs, and political parties, but its 25-percent limit on contributions from non-Vermont residents and organizations is unconstitutional; the statute’s application to wholly independent-expenditure PACs requires further proceedings.

Landell v. Sorrell · filed 2004-08-18(a), (b), (c), (g)

For the reasons set forth, we affirm the District Court's holdings that the following provisions of Act 64 are constitutional: (1) the limit on contributions that candidates may accept from individuals or political action committees (§ 2805); (2) the limit on contributions that political action committees and political parties may accept from any source (§ 2805(a)); (3) the definition of political parties as including state, county and town entities (§ 2801(5)); and (4) the classification of related expenditures as contributions (§ 2809(a)). We also affirm the District Court's finding that the limits on contributions from non-Vermont residents and organizations (§ 2805(c)) are unconstitutional and we uphold its injunction against enforcement of that provision. We vacate the District Court's injunction against enforcement of the limitation on contributions by political parties to candidates (§ 2805(a)). We also vacate the judgment and remand for further proceedings with respect to the constitutionality of (1) limiting candidate expenditures (§ 2805a); (2) treating the "related expenditures" of third parties as candidate expenditures (§ 2809(b)); (3) restricting the ability of PACs to make wholly independent expenditures, to the extent the Act's provisions are read to impose such restrictions (§§ 2801(4), 2805(g)); and (4) limiting transfers of funds from national to state political party affiliates (§§ 2801(5), 2805(a)-(b)). Finally, we affirm the District Court's injunction against enforcement of Act 64's expenditure limitations, pending further proceedings.

Law changed since Vermont repealed § 2805 on January 23, 2014, through 2013, No. 90 (Adj. Sess.), § 2; new contribution limits in § 2941 took effect January 1, 2015.

Section 2805(a) limits political-committee contributions to $2,000 from a single source, political committee, or political party in a two-year general election cycle, and the court held that this contribution limit could constitutionally be applied to VRLC-FIPE because it was functionally indistinguishable from a committee that contributed to or coordinated with campaigns.

Vermont Right to Life Committee, Inc. v. Sorrell · filed 2014-07-02(a)

“But even if contribution limits would be unconstitutional as applied to independent-expenditure-only groups, VRLC-FIPE would not succeed here. ... Thus, because contribution limits are constitutional as applied to VRLC-PC, we agree with the district court that they also may be applied to VRLC-FIPE.”