Michael A. Nutter v. John Dougherty, Dwight Evans, Chaka Fattah, Jonathan Saidel, and City of Philadelphia

Summary

The Supreme Court of Pennsylvania considered whether the Pennsylvania Election Code preempted Philadelphia's ordinance limiting campaign contributions to candidates for municipal office. The court addressed express, conflict, and field preemption, as well as the scope of Philadelphia's home-rule authority. The court affirmed the Commonwealth Court's conclusion that the Election Code did not preempt the ordinance.

Holdings

1. The Election Code did not preempt Philadelphia's ordinance because the General Assembly had not clearly manifested an intent to occupy the field of campaign-contribution regulation or to prohibit local regulation.
2. The ordinance was not conflict-preempted because the defendants identified no irreconcilable conflict between the ordinance and any express provision of the Election Code.
3. Article VII, Section 6 did not clearly apply to campaign-contribution limits because it concerns the procedures, methods, machinery, electors, and voting involved in holding elections, not the regulation of campaign activity preceding elections.

Questions Presented

1. Whether the Pennsylvania Election Code expressly, by conflict, or by field preemption invalidated Philadelphia's ordinance limiting campaign contributions to candidates for municipal office.
2. Whether Article VII, Section 6 of the Pennsylvania Constitution required uniform statewide regulation of campaign contributions and therefore barred Philadelphia's ordinance.
3. Whether Philadelphia's home-rule authority permitted it to enact the campaign-finance ordinance absent a clear legislative manifestation of preemptive intent.

Disposition

affirmed