Van Hollen v. FEC: Plaintiff's motion for summary judgment and its memorandum of law in support of the motion

The plaintiff, Chris Van Hollen, by his undersigned counsel, and pursuant to Fed. R. Civ. P. 56, the Declaratory Judgment Act, 28 U.S.C. §§ 2201-2201, and the Administrative Procedure Act, 5 U.S.C. § 706(2)(A) & (C), move the Court for a summary judgment declaring that 11 C.F.R. § 104.20(c)(9) promulgated by the Federal Election Commission is “arbitrary, capricious, an abuse of discretion, [and] otherwise not in accordance with law” and “in excess of [the Commission’s] statutory jurisdiction, authority, or limitations,” and vacating and remanding 11 C.F.R. § 104.20(c)(9) to the Commission for further proceedings consistent with the Court’s judgment.