[2] Buckley v. Valeo established a "$1000 cap on individuals' contributions to candidates for federal office" in 1976.

In that year, Zev David Fredman filed suit alleging that "the Missouri statute imposing limits on contributions to candidates for state office violated" a candidates First and Fourteenth Amendment rights.

The Federal District Court upheld the statute on limitations to campaign donations.

The Court of Appeals then reversed the decision finding that "Missouri's interest in avoiding the corruption or the perception of corruption caused by candidates' acceptance of large campaign contributions was insufficient to satisfy Buckly's strict scrutiny standard of review.

"[3][2] Justice John Paul Stevens' concurrence questioned more than two decades of campaign finance jurisprudence, stating: "Money is property; it is not speech."