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Iowa Right to Life Committee, Inc. v. Tooker

Citations: 844 F. Supp. 2d 946; 2012 U.S. Dist. LEXIS 21754; 2012 WL 562418Docket: No. 4:10-cv-416 RP-TJS

Court: District Court, S.D. Iowa; February 6, 2012; Federal District Court

Narrative Opinion Summary

The case involves two summary judgment motions concerning the classification of political committees under Iowa law. The Iowa Right to Life Committee, Inc. (IRTL) challenges Iowa Code sections 68A.102(18) and 68A.402(9), asserting they unconstitutionally classify groups not primarily involved in candidate elections as political committees. The court evaluated these motions under Federal Rule of Civil Procedure 56(a), requiring a demonstration of no genuine issues of material fact. The court deferred judgment on one count pending a decision from the Iowa Supreme Court, which later clarified that corporations exceeding $750 in independent expenditures are considered independent expenditure committees, not political committees or permanent organizations. This clarification led to the dismissal of IRTL's challenge due to lack of standing. The court granted the defendants' motion for summary judgment on Count One and denied IRTL's motion, affirming the application of the Iowa Ethics and Campaign Disclosure Board's definition of an independent expenditure committee. Issues related to cost arguments were not addressed due to the absence of formal submissions.

Legal Issues Addressed

Classification of Political Committees Under Iowa Code

Application: The Iowa Supreme Court clarified that a corporation making over $750 in independent expenditures becomes an independent expenditure committee but not a political committee or permanent organization.

Reasoning: The Iowa Supreme Court clarified that a corporation making over $750 in independent expenditures becomes an independent expenditure committee but not a political committee or permanent organization.

Independent Expenditure Committee Definition

Application: The court adopted the Iowa Ethics and Campaign Disclosure Board's definition of an independent expenditure committee, aligning with the classification provided by the Iowa Supreme Court.

Reasoning: Additionally, the court accepted the Iowa Ethics and Campaign Disclosure Board's definition of an independent expenditure committee for this ruling.

Standing in Constitutional Challenges

Application: IRTL's challenge to the definitions of political committees and permanent organizations was dismissed due to lack of standing following the Iowa Supreme Court's clarification.

Reasoning: Consequently, IRTL cannot challenge the definitions of these terms as it lacks standing.

Summary Judgment Standards Under Federal Rule of Civil Procedure 56(a)

Application: The court evaluates evidence in the light most favorable to the nonmoving party, requiring the moving party to demonstrate the absence of genuine issues of material fact.

Reasoning: Summary judgment is granted if the moving party demonstrates that there are no genuine issues of material fact, and that they are entitled to judgment as a matter of law.