Irvine's Ordinance clearly places a limit on contributions to independent expenditure committees. Although such a restriction burdens speech and associational freedoms, under
Buckley and its progeny such a restriction does not place a severe burden on protected speech and associational freedoms. This is because
Buckley does not consider political contributions to be fully protected political speech. Under
Buckley, political contributions are merely speech by proxy because “the transformation of contributions into political debate involves speech by someone other than the contributor.”
Buckley, 424 U.S. at 21, 96 S.Ct. 612. Viewed in the light of the speech by proxy rationale, The Lincoln Club's contributors (i.e., its dues-paying members) are merely engaging in speech by proxy because it is the Lincoln Club, and not the contributors themselves, that transforms the members' contributions into political debate. Since the contributions themselves are not fully-protected political speech under
Buckley and its progeny, the Ordinance's contribution limit, standing alone, does not warrant strict scrutiny.