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Laws governing foreign spending in ballot measure campaigns
From Ballotpedia
Campaign finance rules for ballot measures differ from those for candidate elections. "Referenda are held on issues, not candidates for public office," wrote the U.S. Supreme Court in 1978 (First National Bank of Boston v. Bellotti).[1] The court has held that spending on ballot measure campaigns is similar to issue advocacy, such as lobbying, in the lawmaking process. In 2012, the Supreme Court affirmed that, under the Federal Elections Campaign Act (FECA), foreign nationals were prohibited from making contributions to candidates. However, FECA "does not bar foreign nationals from issue advocacy," according to the affirmed ruling.[2]
The Federal Election Commission, following the court's orders, has held that ballot measure campaigns are not regulated under FECA. According to the FEC, since ballot measure campaigns are similar to issue advocacy, foreign individuals, corporations, and governments can contribute to them.[3]
At least 19 states have passed laws prohibiting foreign nationals or governments from contributing to ballot measure committees. However, the definition of foreign national may vary by state. Those 19 states are Arkansas, California, Colorado, Indiana, Kansas, Kentucky, Louisiana, Maine, Maryland, Missouri, Montana, Nebraska, Nevada, North Dakota, Ohio, South Dakota, Tennessee, Washington, and Wyoming.
HIGHLIGHTS
This page focuses on foreign contributions to ballot measure committees. To see state laws governing foreign contributions to candidate campaigns, click here.
Bans by state
Nineteen states have enacted laws banning foreign nationals or governments from contributing to ballot measure campaigns. Six states have enacted bans on direct contributions, while 13 states have banned direct and indirect contributions from foreign individuals or entities.[4]
States with bans
The following table compares bans on foreign spending in ballot measure campaigns by state. The table categorizes the contributions covered as either direct or direct and indirect. Direct and indirect contributions include those received straight from the foreign individual or entity and contributions from intermediaries such as indpenedent expenditure committees.
States where foreign principal or foreign national are bolded use the same definition as federal law for those terms. Federal law defines foreign nationals as:[5]
- (a) a foreign principal, which includes:
- (i) a foreign government or political party or
- (ii) an individual, partnership, association, corporation, organization, or any other combination of individuals organized under the laws of or having its principal place of business in a foreign country.
- (b) an individual who is not a citizen of the United States or a U.S. national and who is not a lawful permanent resident.
| Comparison of state bans | ||||
|---|---|---|---|---|
| State | Year | Law | Who the Law Applies To | Regulated Contribution Types |
| Arkansas | 2025 | Arkansas Code, § 7-9 | Persons who are not cizens or lawful permanent residents; foreign governments; foreign political parties; and entities organized under the laws or with principal place of business in a foreign country | Direct and indirect |
| California | 1997 | California Code, Government Code - GOV § 85320 | Foreign governments, foreign principals, and domestic subsidiary of a foreign corporation if the decision to contribute to a ballot measure campaign is made by a management employee of the foreign corporation who is neither a U.S. citizen nor a U.S. permanent resident | Direct and indirect |
| Colorado | 2002 | Article XXVIII, Colorado Constitution | Non-U.S. citizens, foreign governments, and any foreign corporation that does not have the authority to do business in Colorado | Direct |
| Indiana | 2025 | Indiana Code Title 3 | Foreign national | Direct |
| Kansas | 2025 | Kansas Statutes Annotated 25-4180 | Non-U.S. citizens or lawful permanent residents; foreign governments; foreign political parties; entities organized under foreign laws; U.S.-based entities that are wholly or majority owned by foreign nationals, with exceptions | Direct and indirect |
| Kentucky | 2025 | Kentucky Revised Statutes 121 | Non-U.S. citizens or lawful permanent residents; foreign governments; foreign political parties; entities organized under foreign laws; U.S.-based entities that are wholly or majority owned by foreign nationals, with exceptions | Direct and indirect |
| Louisiana | 2025 | Louisiana Revised Statutes § 18:1505.2 | Non-U.S. citizens or lawful permanent residents; foreign governments; foreign political parties; and entities formed under foreign laws or based in a foreign country, unless authorized to do business in Louisiana | Direct and indirect |
| Maine | 2023 | 21-A Maine Revised Statutes §1064 (Question 2) | Foreign governments, including entities with partial (5% or more equity stake) foreign government ownership or control | Direct and indirect |
| Maryland | 2017 | Annotated Code of Maryland, Election Law § 13-236.1 | Foreign principal | Direct and indirect |
| Missouri | 2025 | Revised Statutes of Missouri § 130 | Foreign national defined as Non-U.S. citizens or non-lawful permanent residents; foreign governments; foreign political parties; entities organized under foreign laws or with their principal place of business in a foreign country; U.S.-organized entities that are wholly or majority owned by foreign nationals, with exceptions | Direct and indirect |
| Montana | 2025 | Montana Code Annotated § 13-37-501, 13-37-502, AND 13-37-503 | Foreign national defined as a non-U.S. citizen or lawful permanent resident, foreign government, foreign political party, an entity organized under the laws of a foreign country or has its place of business in a foreign country, and any U.S. entity wholly or majority owned by any foreign national, unless the entity's employees pay state income tax and the entity pays state property taxes or ballot measure contributions are derived entirely from funds generated by its U.S. operations and are made by individuals who are U.S. citizens or permanent residents. | Direct and indirect |
| Nebraska | 2022 | Nebraska Revised Statute 49-1479.03 | Foreign national defined as a person who is not a U.S. citizen or national and who is not lawfully admitted for permanent residence; a person, other than an individual, organized under the laws of or having its principal place of business in a foreign country; a government of a foreign country; or a political party or political committee established in a foreign country. | Direct and indirect |
| Nevada | 2011 | Nevada Revised Statutes 294A.325 | Foreign national | Direct and indirect |
| North Dakota | 2018 | Article XIV, North Dakota Constitution | Foreign national defined as a foreign government; foreign political party; foreign corporation, partnership, association, organization, or other entities organized under the laws of or having its principal place of business in a foreign country; foreign citizens; or a person who is not a U.S. citizen or national and has not been lawfully admitted to reside permanently in the U.S. | Direct |
| Ohio | 2024 | Ohio Revised Code Section 3517.121 | Foreign national defined as a person who is not a U.S. citizen; a foreign government or political subdivision; a foreign political party; or a person that is organized under the laws of or has its principal place of business in a foreign country | Direct and indirect |
| South Dakota | 2007 | South Dakota Codified Laws 12-27-21 | Foreign government | Direct |
| Tennessee | 2025 | Tennessee Code Annotated 2-10-501 | Foreign national | Direct and indirect |
| Washington | 2020 | Revised Code of Washington 42.17A.417 | Foreign national defined as a person who is not a U.S. citizen or national; a foreign government or political subdivision; a foreign political party; or a person that is organized under the laws of or has its principal place of business in a foreign country | Direct |
| Wyoming | 2025 | Wyoming Statutes 22‑24‑202 and 22‑25‑116 | Foreign national | Direct and indirect |
Legislation
The following is a list of bills passed, beginning in 2016, related to bans on foreign spending in ballot measure campaigns.
2025
- Arkansas House Bill 1837: The bill was designed to prohibit foreign nationals from directly or indirectly contributing to ballot measure committees or from directing, controlling, or soliciting related contributions or expenditures. It requires committees to affirm that they have not knowingly or willfully received, solicited, or accepted contributions or expenditures from foreign nationals. The committee treasurer must also affirm, to the best of their knowledge, that each donor is not a foreign national and has not received more than $10,000 from prohibited sources within the past four years.[6]
- Indiana House Bill 1467: The bill was designed to prohibit foreign nationals from contributing to ballot measures PACs or directing, controlling, or soliciting related contributions or expenditures. It required PAC treasurers to obtain statements from contributors and mandate 48-hour reports from individuals making certain independent expenditures, certifying they have not accepted over $50,000 from foreign nationals in the past four years and will not do so for the rest of the year.[7]
- Kansas House Bill 2106: The bill was designed to require ballot measure campaign finance reports to include a certification stating: (1) the filer has not knowingly accepted any contributions or expenditures—directly or indirectly—from a foreign national, and (2) each donor listed is not a foreign national and has not knowingly received more than $100,000 in contributions or expenditures from a foreign national within the four years before making their contribution or expenditure. The definition of foreign national did not include lawful permanent residents.[8]
- Kentucky House Bill 45: The bill was designed to prohibit foreign nationals from directly or indirectly contributing to, soliciting for, or influencing decisions related to ballot measures. The bill also prohibited political issues committees from knowingly accepting funds directly or indirectly from foreign nationals. The definition of foreign national did not include lawful permanent residents.[9]
- Louisiana House Bill 693: The legislation made changes to campaign finance law in Louisiana, including prohibiting foreign nationals from directly or indirectly making or promising to make contributions in connection with a ballot measure, the recall of a public officer, or any political committee, expanding on the existing ban related to elections for political office.[10]
- Missouri Senate Bill 152: The legislation prohibited ballot measure committees from using funds from foreign nationals for campaign activities and from accepting contributions or in-kind support from foreign nationals or from individuals or entities that received such contributions. It also required donors contributing over $2,000 to certify that they are not foreign nationals and have not received more than $10,000 from foreign nationals within a four-year period.[11]
- Montana House Bill 818: Prohibits foreign nationals from directly or indirectly making a contribution or expenditure in connection with a statewide ballot measure.[12]
- Tennessee House Bill 888: The bill was designed to prohibit foreign nationals from directly or indirectly making a contribution or expenditure to influence an election on a ballot measure. The bill also requires committee treasurers to obtain an affirmation from donors stating that the donor is not a foreign national and has not knowingly or willfully accepted funds aggregating in excess of $100,000 from prohibited sources within the four-year period immediately preceding the date the contribution is made.[13]
- Wyoming House Bill 337: The bill was designed to prohibit foreign nationals from donating directly or indirectly to ballot measure committees.[14]
2024
- Ohio House Bill 1: The legislation was designed to prohibit foreign nationals from making contributions or expenditures to support or oppose candidates for elective office or statewide certified or potential ballot measures. This would include making contributions indirectly through another person or organization.[15]
2022
- Florida House Bill 921: The legislation was designed to make multiple changes to campaign finance rules regarding ballot measures, including a provision to prohibit an out-of-state donor from giving more than $3,000 to support or oppose an initiative during signature gathering and to prohibit a political action committee that does not have an office in Florida from accepting a contribution of more than $3,000 and a provision banning political contributions surrounding Florida elections from foreign nationals.[16]
- On June 15, 2022, U.S. District Judge Allen Winsor issued a permanent injunction against the bill, blocking the changes from taking effect.[17]
- Nebraska Legislative Bill 843: The bill was designed to make several changes to election law, including prohibiting a foreign national, directly or indirectly, from making a contribution to a ballot question committee or for a ballot question committee to solicit, accept, or receive such a contribution.
2021
- Maine Legislative Document 194 (Vetoed): The legislation would have prohibited contributions and expenditures to influence ballot measures from entities with 10% or more ownership by foreign governments. On June 23, 2021, Gov. Janet Mills (D) vetoed LB 194.[18]
2017
- Maryland Senate Bill 130: The bill was designed to prohibit any foreign government, political party, individual, partnership, association, corporation, organization or other foreign principal from contributing to a ballot issue campaign or to a person that contributes to support or oppose a ballot issue.
- North Dakota House Bill 1234: The bill was designed to prohibit political or election-related contributions from foreign governments, parties, corporations, or individuals.
Ballotpedia tracked four ballot measures related to foreign spending in ballot measure campaigns.
| State | Year | Measure | Type | Description | Outcome |
|---|---|---|---|---|---|
| Maine | 2023 | Question 2 | IndISS | Prohibits foreign governments, or entities with at least 5% foreign government ownership or control, from spending money to influence ballot measures or candidate elections |  |
| North Dakota | 2018 | Measure 1 | CICA | Ban political contributions from foreign government entities, foreign individuals, and foreign corporations | |
| Missouri | 2016 | Constitutional Amendment 2 | CICA | Ban committees from accepting contributions from foreign corporations[19] | / |
| Colorado | 2002 | Amendment 27 | CICA | Prohibits candidate committees and political parties from making or accepting certain contributions | |
Ongoing litigation
- In Kansas, Kansans for Constitutional Freedom v. Kobach: On June 30, U.S. District Court Judge Daniel Crabtree denied an injunction on Kansas House Bill 45, which prohibited ballot measure campaigns from accepting contributions from foreign nationals.
- Ruling: Judge Crabtree concluded, "Subjecting HB 2106 to strict scrutiny, the court decides that Kansas likely has a compelling interest in limiting foreign influence in its constitutional amendment ballot issue elections." He wrote, "Defendants thus argue that Bluman’s compelling interest applies with equal force—or even greater force—to ballot issues. Defendants have the better end of this argument. After all, ballot issues implicate democratic self-government even more directly than candidate advocacy. ... And the ballot issues at stake here, state constitutional amendments, shape the state’s most foundational document."[20]
- Ruling: Judge Crabtree concluded, "Subjecting HB 2106 to strict scrutiny, the court decides that Kansas likely has a compelling interest in limiting foreign influence in its constitutional amendment ballot issue elections." He wrote, "Defendants thus argue that Bluman’s compelling interest applies with equal force—or even greater force—to ballot issues. Defendants have the better end of this argument. After all, ballot issues implicate democratic self-government even more directly than candidate advocacy. ... And the ballot issues at stake here, state constitutional amendments, shape the state’s most foundational document."[20]
- In Ohio, OPAWL - Building AAPI Feminist Leadership, et al. v. Yost: On October 8, 2024, the U.S. Court of Appeals for the Sixth Circuit denied an injunction on Ohio House Bill 1, which prohibited foreign nationals, including lawful permanent residents, from making contributions to support or oppose a statewide ballot measure. The three-judge panel issued a 2-1 decision. Judge Amul Thapar wrote the court's opinion, with Judge David McKeague concurring. Judge Stephanie Dawkins Davis dissented.
- Ruling: Judge Thapar cited Bluman v. FEC, writing that the state has a compelling interest in limiting non-citizens’ participation in democratic self-government. He wrote, "... advocacy around ballot initiatives is even more connected to the democratic process than advocacy for or against a candidate. Ballot initiatives are the quintessential form of direct democracy. ... The compelling interest identified by the Supreme Court amounts to preventing influence by all those without American citizenship, including lawful permanent residents, over America’s 'process of democratic self-government.'"
- Dissent: Judge Davis wrote, "Absent such evidence, nothing is obvious about LPRs [lawful permanent residents] being the source of Ohio’s concerns. Speculative fear does not satisfy either intermediate or strict scrutiny." She also cited Citizens Against Rent Control v. City of Berkeley, stating, "And notably, as regards the constitutional protection afforded contributions for ballot initiatives, the Supreme Court has observed that ‘there is no significant state or public interest in curtailing debate and discussion of a ballot measure.’"
- In Maine, Central Maine Power Company v. Maine Commission on Governmental Ethics and Election Practices: On July 11, 2025, the First Circuit Court of Appeals upheld a district court's injunction on Maine Question 2, which prohibited foreign governments, or entities with at least 5% foreign government ownership or control, from making expenditures to influence ballot measure elections.[21]
- Ruling: Judges Lara Montecalvo, Jeffrey Howard, and Seth Aframe issued an unanimous order, holding that: "The law is overinclusive because ... it silences U.S. corporations that have their own First Amendment rights: CMP and Versant were founded in Maine, have operated exclusively there for over a century, and are entirely run by U.S. citizens... [evidence] does not demonstrate why the 5% threshold—as opposed to 100%, or 50%, or any other number—is narrowly tailored to its interests in preventing foreign influence in its elections. ... In the face of these examples, the 5% threshold starts to look either like an end-run around Citizens United, aimed at silencing a large swath of corporations merely because they are corporations, or an effort to shape the ongoing debate in Maine about its two primary utility companies by silencing one side—the companies themselves."
- Appealed from U.S. District Court for Maine: On February 29, 2024, the U.S. District Court Judge Nancy Torresen granted an injunction, stating, "The 5% threshold would deprive the United States citizen shareholders—potentially as much as 95% of an entity’s shareholders—of their First Amendment right to engage in campaign spending. Simply put, it would be overinclusive."[22]
- Buckley v. Valeo (1976): The United States Supreme Court determined a distinction between contributions and expenditures; while upholding the Federal Election Campaign Act (FECA) federal campaign contribution limits, the court overturned limits on independent expenditures, including those for ballot measure campaigns.[23]
- The majority ruled that limits on campaign contributions "served the government's interest in safeguarding the integrity of elections," but, citing First Amendment concerns felt that the effect of "expenditure limitations is to restrict the quantity of campaign speech by individuals, groups and candidates." The decision acknowledged that restrictions on campaign limits and expenditures both have potential First Amendment implications, but that the FECA's limitations on expenditures constituted "significantly more severe restrictions on protected freedom of political expression and association than do its limitations on financial contributions."[23]
- First National Bank of Boston v. Bellotti (1978): The United States Supreme Court ruled that the First Amendment of the U.S. Constitution authorizes all individuals and corporations to discuss matters of public concern without the threat of punishment. The case revolved around a group of national banks and corporations planning to use their money to publicize their opposition to a ballot initiative. The Massachusetts Attorney General claimed that corporations could not make expenditures to influence the outcome of an election that did not directly impact their business, pursuant to a state statute. The corporations filed a lawsuit, arguing that the state statute violated their First Amendment rights.[24]
- Justice Lewis Powell, writing for the court, argued that the right to attempt to influence the outcome of an election is protected by the First Amendment. Powell contended that the protection of free speech was not diminished by the fact that the case involved a corporation as opposed to an individual. The court also distinguished campaign finance rules for ballot measures versus candidates, saying, "Referenda are held on issues, not candidates for public office."[24]
- Justice Byron White dissented, saying, "This unanimity of purpose breaks down, however, when corporations make expenditures or undertake activities designed to influence the opinion or votes of the general public on political and social issues that have no material connection with or effect upon their business, property, or assets. Although it is arguable that corporations make such expenditures because their managers believe that it is in the corporations' economic interest to do so, there is no basis whatsoever for concluding that these views are expressive of the heterogeneous beliefs of their shareholders whose convictions on many political issues are undoubtedly shaped by considerations other than a desire to endorse any electoral or ideological cause which would tend to increase the value of a particular corporate investment."[24]
- Citizens Against Rent Control v. City of Berkeley (1981): The United States Supreme Court ruled that an ordinance adopted by the voters of Berkeley, California to limit contributions to ballot measure committees to $250 violated the First Amendment. The opinion also differentiated ballot measure committees from candidate committees, noting that limits on candidate committees, per Buckley v. Valeo, were to prevent quid pro quo corruption or the appearance of quid pro quo corruption. Since ballot measures are not suspect to quid pro quo corruption, according to the majority's opinion, "there is no significant state or public interest in curtailing debate and discussion of a ballot measure."[25]
- Chief Justice Warren Burger writing for the majority said, "To place a Spartan limit or indeed any limit-on individuals wishing to band together to advance their views on a ballot measure, while placing none on individuals acting alone, is clearly a restraint on the right of association. ... Whatever may be the state interest or degree of that interest in regulating and limiting contributions to or expenditures of a candidate or a candidate's committees, there is no significant state or public interest in curtailing debate and discussion of a ballot measure. Placing limits on contributions, which, in turn, limits expenditures, plainly impairs freedom of expression."[25]
- Justice Byron White dissented saying, " Recognition that enormous contributions from a few institutional sources can overshadow the efforts of individuals may have discouraged participation in ballot measure campaigns and undermined public confidence in the referendum process. By restricting the size of contributions, the Berkeley ordinance requires major contributors to communicate directly with the voters. If the ordinance has an ultimate impact on speech, it will be to assure that a diversity of views will be presented to the voters."[25]
- McIntyre v. Ohio Elections Commission (1995): The United States Supreme Court ruled that the Federal Election Campaign Act (FECA) "regulates only candidate elections, not referenda or other issue-based ballot measures." FECA defines elections as "the process by which individuals, whether opposed or unopposed, seek nomination for election, or election." That definition does not include ballot measures.[26]
- Bluman v. Federal Election Commission (2011): The U.S. Supreme Court upheld the U.S. District Court for the District of Columbia's ruling that held that FECA prohibits foreign contributions to political candidates, but not ballot measure campaigns, and that this prohibition is constitutional.[27]
- Judge Brett Kavanaugh, writing the majority opinion said, "[the law] does not bar foreign nationals from issue advocacy—that is, speech that does not expressly advocate the election or defeat of a specific candidate."[27]
The following is a selection of Federal Election Commission orders and advisory opinions regulating ballot measure campaigns:
- MUR 7523 (2021): The FEC held that the federal ban on foreign political contributions concerns candidate elections, not ballot measure campaigns. Therefore, the FEC affirmed that foreign individuals, corporations, and governments could contribute to ballot measure campaigns. The opinion originated with Montana I-186, which regarded mining permits. In 2018, voters rejected I-186. Opponents received funding from Sandfire, a Canadian subsidiary of an Australian mining company.
- MUR 6678 (2015): The FEC held that the use of the term election in the FECA only applied to candidate elections, excluding state and local ballot measure contributions from the federal government's ban on foreign nationals contributing to elections. The order was related to a local ballot measure campaign in Los Angeles County in 2012.
- Concurring Opinion in Advisory Opinion 2010-07 (2010): The FEC held that ballot measure elections are not considered elections under FECA and therefore federal candidates seeking contributions on behalf of ballot measure campaigns are not subject to the foreign national prohibition or amount limitations prior to the ballot measure being certified for the ballot. The order was related to a Proposition 20 (2010), which was sponsored by Yes on FAIR and related to congressional redistricting.
- Advisory Opinion 2005-10 (2005): The FEC held that the soft money restrictions in the Bipartisan Campaign Finance Reform Act (BCRA) do not apply to federal officeholders raising money for ballot measure committees that are not directly or indirectly financed or controlled by that officeholder. The opinion related to several ballot initiatives aiming to qualify for the 2005 California ballot.
- Advisory Opinion 1989-32 (1989): The FEC affirmed that foreign nationals could contribute to ballot initiative campaigns but not to candidate committees.
- Advisory Opinion 1984-62: The FEC wrote in the opinion that "[t]he Commission has previously held that contributions or expenditures exclusively to influence ballot referenda issues are not subject to the [FECA]."
The following is a list of recent campaign finance bills related to campaign contributions from foreign individuals or entities. To learn more about each of these bills, click the bill title. This information is provided by BillTrack50 and LegiScan.
See also
Footnotes
- ↑ U.S. Supreme Court, "First National Bank of Boston v. Bellotti," April 26, 1978
- ↑ FEC, "MUR: 6678," April 30, 2015
- ↑ FEC, "Stop 1-186 to Protect Mining and Jobs ," accessed December 14, 2022
- ↑ Democracy Policy Network, "Foreign Investor Electioneering Ban," accessed October 19, 2023
- ↑ Legal Information Institute, Cornell University Law School, "52 U.S. Code § 30121 - Contributions and donations by foreign nationals," accessed June 14, 2024
- ↑ Arkansas State Legislature, "House Bill 1837," accessed April 28, 2025
- ↑ Indiana State Legislature, "House Bill 1467," accessed April 11, 2025
- ↑ Kansas State Legislature, "House Bill 2106," accessed April 8, 2025
- ↑ Kentucky State Legislature, "House Bill 45," accessed April 4, 2025
- ↑ Louisiana State Legislature, "House Bill 693," accessed June 27, 2025
- ↑ Missouri Senate, "SB 152," accessed July 9, 2025
- ↑ Montana Legislature, "HB 818," accessed May 22, 2025
- ↑ Tennessee General Assembly, "HB 888," accessed May 22, 2025
- ↑ Wyoming State Legislature, "HB 337," accessed March 7, 2025
- ↑ Ohio State Legislature, "House Bill 1," accessed June 13, 2024
- ↑ Florida State Senate, "House Bill 921," accessed June 14, 2023
- ↑ News4Jax, "Judge strikes down law limiting ballot initiative donations," accessed June 16, 2022
- ↑ Maine State Legislature, "Legislative Document 194," accessed June 20, 2023
- ↑ The ban was ruled unconstitutional.
- ↑ United States District Court for the District of Kansas, "Kansans for Constitutional Freedom v. Kobach," June 30, 2025
- ↑ United States Court of Appeals for the First Circuit, "Central Maine Power Company v. Maine Commission on Governmental Ethics and Election Practices," July 11, 2025
- ↑ United States District Court for the District of Maine, "Maine Power Company v. Maine Commission on Governmental Ethics and Election Practices," February 29, 2024
- ↑ 23.0 23.1 Case Law, "BUCKLEY v. VALEO, (1976)," accessed December 27, 2016
- ↑ 24.0 24.1 24.2 Oyez, "First National Bank of Boston v. Bellotti," accessed August 8, 2022
- ↑ 25.0 25.1 25.2 U.S. Supreme Court, "Citizens Against Rent Control v. City of Berkeley," decided December 14, 1981
- ↑ [Harold J. Spaeth, Lee Epstein, et al., "2023 Supreme Court Database, Version 2023 Release 1 and SCDB Legacy 07," accessed March 21, 2024]
- ↑ 27.0 27.1 FEC, Bluman v. Federal Election Commission (2011), decided August 8, 2011
