San Jose Silicon Valley Chamber of Commerce Political Action Committee v. City of San Jose

In July 2006, the local chamber of commerce (COMPAC) challenged San Jose’s limits on contributions to political committees making only independent expenditures in municipal elections.  COMPAC argued that independent expenditures did not give rise to corruption or the appearance of corruption, and that consequently there was no constitutional rationale for a limit on contributions to a committee making only independent expenditures.  The district court struck down the limits on September 20, 2006.  On October 14, 2008, the Ninth Circuit vacated the district court’s decision, holding that the district court should have abstained from hearing the case because the San Jose Elections Commission was conducting an ongoing state administrative proceeding against COMPAC.