In Geier v. Missouri Ethics Commission, the appellant, Gerald Geier, asked the Supreme Court of Missouri to consider the constitutionality of Missouri’s reporting requirement statutes as applied to Stop Now!, an inactive political action committee (“PAC”). Geier argued that the reporting requirement failed to meet the exacting scrutiny standard because the State’s interest in receiving reports of inactivity did not outweigh the burden placed on Geier by the requirement. This Note analyzes the court’s application of exacting scrutiny in the instant decision. It also notes the limits of PAC disclosure requirements as a public policy tool in the absence of sensible laws regarding what is and is not a PAC and discusses the practical import of narrow disclosure regulations in an era increasingly dominated by unlimited and independent political expenditures. The limits of Missouri’s PAC disclosure requirements, illuminated by the court’s reasoning in the instant decision, will continue to hinder the average Missouri citizen’s ability to participate in his or her democracy, while enabling the richest Missourians to operate in the shade, away from the disinfecting light envisioned by Justice Brandeis.

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