ELECTION LAW
United States District Court, District of Alaska (2022)
Kristiana Olson
In Smith v. Helzer, 2022 WL 2757421 (D. Alaska 2022), the district court denied a request to
enjoin the enforcement provisions requiring disclosures for political donations. (Id. at *14). In
2020, Alaskans enacted changes to the election system by ballot measure, including additional
campaign finance disclosures. (Id. at *1). These provisions mandated disclosure of donors
contributing more than $2,000 per year to any person or organization that makes election
expenditures, required disclaimers for political communications, and disallowed “dark money”
contributions over $2,000. (Id. at *1–2). The plaintiffs argued that these donor disclosure
requirements were unconstitutional because they required donors to report donations even when
recipients were also required to report them, and even when the recipients were not actively
engaged in qualifying expenditures. (Id. at *4). The district court held that the disclosure
requirements withstood exacting scrutiny, because there was a substantial relation between the
disclosure and the sufficiently important government interest. (Id. at *4–5). Providing voters with
the source of election funds was a sufficiently important governmental interest, and requiring
disclosure was not unduly burdensome or duplicative. (Id.). Therefore the district court denied the
request to enjoin the enforcement provisions requiring disclosures for political donations. (Id. at
*14).
