The case centers on Measure B, the Oxnard Government Accountability and Ethics Act, which 82% of the city's voters approved on March 3, 2020. Measure B capped individual contributions to City Council candidates at $500 per election and contributions to citywide candidates — for Mayor, City Clerk, and City Treasurer — at $750, with higher limits for political action committees and no limits at all on political parties. Moving Oxnard Forward, Inc., a political advocacy nonprofit, sued the city clerk in her official capacity, arguing that the per-candidate limits violated the First Amendment and that the aggregate limits violated both the First and Fourteenth Amendments.
The majority, authored by Judge Koh, held that Oxnard cleared the threshold burden of demonstrating a sufficiently important governmental interest in preventing quid pro quo corruption or its appearance. The court pointed to four pieces of evidence: a Ventura County Star newspaper article alleging corruption by city officials; a District Attorney investigation that produced a report detailing city officials receiving private jet travel, Lakers tickets, Dodgers tickets, Broadway show tickets, golf rounds, and meals from companies doing business with the city — followed by official actions benefiting those same companies; a resident survey showing 77% support for a government accountability measure; and the 82% vote approving Measure B itself. The court held that this evidence satisfied the standard articulated in Nixon v. Shrink Missouri Government PAC and the circuit's own Lair v. Motl, which it described as a low evidentiary bar requiring only that the perceived threat of corruption be more than mere conjecture.
Turning to whether the limits were closely drawn, the majority walked through the four Randall v. Sorrell danger signs. It held that the first three were absent: Measure B's limits run per candidate per election rather than per office per election cycle; political parties face no limits at all; and the city's expert showed Oxnard's limits are near the median for California cities of comparable population. On a per-resident and per-registered-voter basis, the city's citywide limit is greater than the limits in Los Angeles, San Diego, and San Jose; on an absolute dollar, per-resident, and per-registered-voter basis, it is greater than the limits in San Francisco and Oakland. The court assumed without deciding that the fourth danger sign — whether the limit falls below those previously upheld by the Supreme Court — was present, because the Supreme Court has never addressed city-level contribution limits specifically. Proceeding to independent review of the record, the majority evaluated the five Randall tailoring considerations and held that four favored Measure B: the limits would not significantly restrict challengers' fundraising (93.7% of 2018 donors gave within the caps); political parties are exempt; volunteer travel and home-event expenses are excluded from the contribution calculation; and the limits are adjusted for inflation by the City Clerk's calculation every two years under a Consumer Price Index formula, with the City Council required to adopt the adjusted limits by resolution. Because four of the five considerations favored the city, the court held that the fifth consideration — whether a special justification existed — was irrelevant, and affirmed summary judgment for the city on both the per-candidate and aggregate contribution claims.
Judge Collins, joined by Judge VanDyke, dissented on both steps of the analysis. On the threshold question, Collins argued that the Lair and Eddleman standards are inconsistent with current Supreme Court authority and should have been overruled en banc, because Citizens United and McCutcheon require evidence substantiating a genuine concern about quid pro quo corruption in the specific context being regulated — not merely evidence of gift-taking scandals unrelated to campaign contributions. He noted that the District Attorney's Report affirmatively concluded there was insufficient evidence to prove the most serious allegations and that the Report itself did not identify campaign contributions as a source of corruption or recommend contribution limits as a remedy. On the tailoring question, Collins argued that Randall's list of danger signs is not exhaustive and that Buckley itself recognizes invidious discrimination against challengers as a constitutional risk warranting independent scrutiny. He contended the record showed sufficient danger signs of invidious discrimination against Aaron Starr, the nonprofit's president and a frequent challenger of the incumbent city council, whose fundraising practices the city's own PowerPoint presentation used as the central example for why limits were needed, and against whom the city's elected officials had a documented history of political conflict. Collins concluded that, upon independent review, the limits are more closely drawn to suppressing Starr's political activity than to combating quid pro quo corruption, and he would have reversed and directed summary judgment for the plaintiff on the per-candidate aggregate contribution limitations.