Libertarian Party of Alaska, Inc. v. State

Summary

The Alaska Supreme Court held that the Alaska Public Offices Commission had authority to promulgate 2 AAC 50.327, requiring political parties to disclose soft-money receipts and expenditures. The court concluded that the regulation was consistent with the Alaska Campaign Disclosure Act, reasonably related to the statute's purposes, and neither unreasonable nor arbitrary. Disclosure of soft money was found to inform voters, deter corruption, and assist enforcement of hard-money limits.

Holdings

1. APOC had at least implied statutory authority to promulgate 2 AAC 50.327 because requiring disclosure of soft money facilitates enforcement of the Act's hard-money limits, deters evasions, and informs the electorate.
2. 2 AAC 50.327 was consistent with the Campaign Disclosure Act and was reasonable and not arbitrary.

Questions Presented

1. Whether APOC had express or implied statutory authority under the Alaska Campaign Disclosure Act and Alaska's Administrative Procedures Act to promulgate 2 AAC 50.327 requiring political parties to disclose soft-money contributions and expenditures.
2. Whether 2 AAC 50.327 was consistent with the Campaign Disclosure Act and was reasonable and not arbitrary.

Disposition

affirmed