JURIST - Paper Chase: Sixth Circuit strikes down Ohio law restricting doctors' campaign contributions

[JURIST] The US Court of Appeals for the Sixth Circuit [official website] on Friday struck down [opinion, PDF] a portion of an Ohio law [Ohio Rev Code § 3599.45] that prohibited doctors who treat Medicaid patients from contributing to the political campaigns of candidates for state attorney general or county prosecutor. The Sixth Circuit ruled that the law was an unconstitutional restriction of free speech [AP report] stating "[t]he statute here restricts the First Amendment rights of nearly 100,000 Medicaid providers who do not commit fraud, based on an attenuated concern about a relative handful of providers who do." The Ohio law was enacted in 1978 and it was intended as an anti-corruption measure to protect against Medicaid fraud. The suit was filed by nine Cleveland-area doctors in 2010 after they were told they could not contribute to the re-election campaign of Ohio Attorney General Richard Cordray [official website].

Campaign finance laws have been a contentious issue recently. In June, the US Court of Appeals for the Fourth Circuit [official website] ruled [JURIST report] that a district court erred in holding that corporations can contribute directly to political campaigns. Earlier that month, the Supreme Court struck down [JURIST report] a Montana campaign finance law that restricted the amount of money corporations can spend on campaigns, holding that Citizens United v. Federal Election Commission [opinion, PDF] invalidated the Montana law. That decision, American Tradition Partnership, Inc. v. Bullock [SCOTUSblog backgrounder] reversed a decision by the Montana Supreme Court upholding the law [JURIST report]. In February, the Supreme Court blocked enforcement [JURIST report] of the Montana Supreme Court ruling.