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

Defendant City of San Jose enacted a campaign finance reform measure, including San Jose Municipal Code section 12.06.310, that requires political organizations to collect no more than $250 per person for campaigning in certain local elections. Plaintiffs San Jose Silicon Valley Chamber of Commerce Political Action Committee and COMPAC Issues Fund, which are local political organizations, collected more than $250 per person and actively campaigned in a qualifying local election. Defendant San Jose Elections Commission, the local governmental entity established by the City to enforce its campaign finance laws, investigated Plaintiffs’ activities and concluded that Plaintiffs had violated section 12.06.310. The Commission decided to issue a public reprimand and to assess a fine against Plaintiffs.

After the Commission issued a public reprimand, but before it could assess the fíne, Plaintiffs filed this 42 U.S.C. § 1983 action in federal district court. The district court denied Defendants’ motion for judgment on the pleadings, which asked the court to abstain under Younger v. Harris, 401 U.S. 37 , 91 S.Ct. 746 , 27 L.Ed.2d 669 (1971). The court held that the contributions limit was…