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Because the government's justification for campaign regulations is generally related to <br />corruption or the appearance of impropriety, when an Independent Expenditure <br />Committee makes an expenditure in support or in opposition to a candidate or ballot <br />measure, and there is no coordination between the Independent Expenditure <br />Committee and the targeted candidate, the government may not restrict such <br />expenditures. The U.S. Supreme Court has ruled that the absence of coordination <br />minimizes the chance that the expenditure is being made in exchange for political <br />favors. <br />Similarly, limits on contributions by persons, businesses or organizations to <br />Independent Expenditure Committees are not advisable because the same lack of <br />coordination lessens the government's interest in the appearance of impropriety or <br />actual corruption. However, committees themselves can be subject to a local <br />contribution limitation to a candidate or a candidate's committee. <br />Providing Direction to Staff about Limits on Contributions. If the City <br />Council considers enacting an ordinance to limit campaign contributions to <br />candidates for local office, the City Council should advise staff: <br />- Whether the contribution limit should apply to an Independent Expenditure <br />Committee making a contribution to a candidate or candidate's committee. <br />Contribution Reporting Threshold. <br />The Council may consider modifying the current $25 campaign contribution reporting <br />threshold. Under State law, $100 is the threshold at which a candidate or committee <br />must report the name, address and occupation of each person or organization making a <br />contribution. <br />In the Tri-Valley, both Dublin and San Ramon utilize the State's $100 reporting <br />threshold. Livermore's reporting threshold is $25. <br />Providing Direction to Staff about Contribution Reporting Threshold. If the <br />City Council considers modifying the threshold to report campaign <br />contributions, the City Council should provide staff direction about: <br />- Whether the new reporting threshold would be the $100 amount set by <br />State law, or some other amount between $25 and $100. <br />Conclusion. <br />Based on the authority delegated by State law, the City Council may adopt local <br />campaign contribution limits for candidates and candidates' committees for the offices of <br />mayor and council member. If considered, the City Council should advise staff <br />regarding: <br />Page 5 of 6 <br />