fec national right work committee argued november decided december federal election campaign act prohibits corporations labor unions making contributions expenditures connection federal elections section however permits participation unions corporations federal electoral process allowing organizations establish pay expenses separate segregated funds may used political purposes federal elections act restricts operations segregated funds several respects relevance provide corporation without capital stock may solicit contributions fund established members corporation respondent national right work committee nrwc corporation without capital stock solicited persons contributions separate segregated fund sponsored petitioner federal election commission determined nrwc solicitation violated persons solicited members among things nrwc solicitation letters mention membership articles incorporation disclaim existence members members play part operation administration corporation held persons solicited nrwc insufficiently attached corporation qualify members interpretation act raise constitutional difficulties pp first amendment associational rights asserted nrwc overborne interests congress sought protect enacting provision marks culmination careful legislative adjustment federal electoral laws prevent actual apparent corruption reflects legislative judgment special characteristics corporations require prophylactic measures pp rehnquist delivered opinion unanimous charles steele argued cause petitioners briefs richard bader miriam aguiar jeffrey bowman richard mansfield iii argued cause respondents brief george webster edith hakola richard clair albert woll laurence gold margaret mccormick filed brief american federation labor congress industrial organizations amicus curiae urging reversal richard mayberry filed brief public service research council et al amici curiae urging affirmance justice rehnquist delivered opinion question case ultimately comes whether respondent national right work committee nrwc respondent limited solicitation funds members within meaning april petitioner federal election commission commission determined probable cause believe nrwc violated provisions act soliciting contributions persons members shortly thereafter respondent filed complaint district eastern district virginia seeking injunctive declaratory relief commission one month later commission filed enforcement proceeding respondent district district columbia seeking establish respondent violation actions consolidated latter granted summary judgment favor commission basis stipulated facts supp judgment district reversed appeals district columbia circuit app granted certiorari respondent nrwc nonprofit corporation without capital stock organized laws commonwealth virginia given central role congressional use word member litigation useful set forth respondent organizational history detail respondent predecessor another corporation merged articles merger filed district columbia successor corporation stated nrwc shall members similar statement contained articles incorporation nrwc presently filed virginia likewise respondent bylaws make reference members membership corporation stated purpose nrwc according virginia articles incorporation help make public aware fact american citizens required join pay dues labor organizations order earn living app pet cert pursuance objective nrwc regularly mails messages millions individuals businesses whose names found way onto commercially available mailing lists organization purchased rented letters mention membership nrwc seek donations help nrwc publicize opposition compulsory unionism frequently contain questionnaire recipient requested answer return late order comply nrwc established separate segregated fund see receive make contributions behalf federal candidates fund denominated employees rights campaign committee ercc operation completely subsidized nrwc treasury paid expenses establishing administering fund soliciting contributions part nrwc sent letters individuals one time contributed soliciting contributions ercc result solicitations fund received contributions october another lobbying group committee effective congress filed complaint ercc commission alleging violation complaint asserted nrwc violated section act using corporate funds solicit contributions ercc persons nrwc stockholders executive administrative personnel families nrwc deny assertions took position recipients solicitation letters members nrwc within proviso set forth commission found probable cause believe violation occurred completing investigative procedures set statute unsuccessfully attempting resolve matter conciliation see supp authorized filing civil enforcement suit litigation followed essential proper resolution case interpretation statement prohibition corporate solicitation contained shall prevent corporation without capital stock soliciting contributions separate segregated fund established corporation without capital stock members corporation emphasis added appeals rejected commission contentions regarding meaning member went hold term embraces least individuals nrwc describes active supporting members app opinion appeals indicates construction reached least part concern constitutional implications narrower construction explained reject construction statutory purpose outlined prohibit contributions expenditures corporations labor organizations connection federal elections section however permits participation unions corporations federal electoral process allowing establish pay administrative expenses separate segregated fund may utilized political purposes act restricts operations segregated funds however making unlawful corporation solicit contributions fund established persons stockholders families executive administrative personnel families finally relevance section quoted proviso pertinent part paragraph shall prevent corporation without capital stock separate segregated fund established corporation without capital stock soliciting contributions fund members sponsoring corporation effect proviso limit solicitation nonprofit corporations persons attached way corporate structure ibid appeals noted construed term member embrace least individuals nrwc describes active supporting members app two categories members recognized nrwc described following terms appeals nrwc attracts members publicizing position issues relating compulsory unionism advertisements personal contacts primarily letters letters describe purpose nrwc urge recipient assist nrwc example writing legislators request financial support ask recipient respond questionnaire determine whether person shares similar political philosophy person response evidences intention support nrwc promoting voluntary unionism qualifies member person responds without contributing financially considered supporting member person responds also contributes considered active member nrwc sends acknowledgement membership card classes regular course operations nrwc members receive newsletters action alerts responses individual requests information respond issue surveys asked communicate elected representatives appropriate see joint vol ii et seq commission however insists standards membership fluid insubstantial come within statutory term member argues comply commission regulation defining term members means persons currently satisfying requirements membership membership organization trade association cooperative corporation without capital stock person considered member definition requirement membership contribution separate segregated fund federal election commission regulations cfr section one several amendments act enacted entire legislative history subsection appears floor statement senator allen introduced provision senate explained purpose amendment language president amendment cure omission bill allow corporations stock membership organization cooperative corporations without capital stock hence without stockholders set separate segregated political funds solicit contributions membership since stockholders solicit allowed solicit members amendment provides cover omission bill believe agree filled cong rec also assume since body federal law corporations see burks lasker congress intended least reference laws various dealing nonprofit corporations analogous situation congress authorized state taxation real property subsidiaries reconstruction finance corporation said think congressional purpose best accomplished application settled state rules constitutes real property long plain state rules effect discrimination government patently run counter terms act rfc beaver county apparently permit nonprofit corporations members similar shareholders business corporation although state statutes generally seem require form organization see model nonprofit corporation act many board directors nonprofit corporation may autonomous body given wide variety treatment subject membership state incorporation laws focus commission regulation corporation standards think entirely permissible commission case look nrwc corporate charter laws virginia bylaws adopted accordance charter applying statutory language interpret facts case think congress intend allow individuals solicited nrwc come within exclusion members although membership cards ultimately sent either contribute respond way respondent mailings solicitation letters make reference members members play part operation administration corporation elect corporate officials indeed apparently membership meetings indication nrwc asserted members exercise control expenditure contributions moreover previously noted nrwc articles incorporation publicly filed documents explicitly disclaimed existence members think circumstances solicited insufficiently attached corporate structure nrwc qualify members statutory proviso unlike appeals think construction statute raises insurmountable constitutional difficulties appeals expressed view sort solicitations involved neither corrupt officials coerce members corporation holding minority political views two goals believed congress mind enacting statutory provisions issue appeals apparently thought respondent argues term members must given elastic definition order prevent impermissible interference constitutional rights enunciated cases naacp button schaumburg citizens better environment similarly respondent places considerable reliance statement buckley valeo decisions involving associational freedoms establish right association basic constitutional freedom kusper pontikes closely allied freedom speech right like free speech lies foundation free society shelton tucker see bates little rock naacp alabama naacp button supra harlan dissenting view fundamental nature right associate governmental action may effect curtailing freedom associate subject closest scrutiny naacp alabama supra fully subscribe views stated buckley next sentence passage quoted respondent went say yet clear either right associate right participate political activities absolute csc letter carriers ibid place respondent constitutional claims proper perspective repeat language used buckley valeo supra constitutional power congress regulate federal elections well established questioned parties case agree petitioners purposes sufficient justify regulation issue speaking corporate involvement electoral politics recently said overriding concern behind enactment statutes federal corrupt practices act problem corruption elected representatives creation political debts importance governmental interest preventing occurrence never doubted first national bank boston bellotti citations omitted also convinced statutory prohibitions exceptions considered sufficiently tailored purposes avoid undue restriction associational interests asserted respondent history movement regulate political contributions expenditures corporations labor unions set forth great detail automobile workers supra need summarize development years ago congress first made financial contributions federal candidates corporations illegal enacting tillman act ch stat within next years congress went required financial disclosure federal candidates following election act june ch stat following year required disclosure well act ch stat federal corrupt practices act passed extended prohibition corporate contributions include anything value made acceptance corporate contribution well giving contribution crime stat first restrictions union contributions contained second hatch act stat later war labor disputes act stat union contributions connection federal elections prohibited altogether prohibitions union political activity extended strengthened act stat broadened earlier prohibition contributions expenditures well congress codified provisions federal election campaign act stat enacted later amendments stat stat stat section legislative history indicates merely refinement gradual development federal election statute careful legislative adjustment federal electoral laws cautious advance step step nlrb jones laughlin steel account particular legal economic attributes corporations labor organizations warrants considerable deference see rostker goldberg discuss also reflects permissible assessment dangers posed entities electoral process order prevent actual apparent corruption congress aimed part regulatory scheme corporations statute reflects legislative judgment special characteristics corporate structure require particularly careful regulation see morton salt restricts solicitation corporations labor unions without great financial resources well fortunately situated accept congress judgment potential influence demands regulation legislative determination need prophylactic measures corruption evil feared said california medical assn fec differing structures purposes different entities may require different forms regulation order protect integrity electoral process accept view solicitation limited past proved philosophically compatible views corporation must permitted statute order prohibition constitutional ignore teachings earlier decisions governmental interest preventing actual corruption appearance corruption elected representatives long recognized first national bank boston bellotti supra reason may case accomplished treating unions corporations similar organizations differently individuals california medical assn fec supra respondent also asserts claim unconstitutional vagueness relying additional cases connally general construction grayned city rockford speiser randall smith california think vagueness claim adequately answered language quoted earlier csc letter carriers may one way statute go determining members nonprofit corporation statute may leave room uncertainty periphery exception solicitation members however record satisfied nrwc activities extended large part toto people members reasonable interpretation statute see broadrick oklahoma judgment appeals reversed ordered footnotes commission independent administrative agency vested exclusive jurisdiction civil enforcement act see supp relief awarded commission district included declaratory judgment unconstitutional order nrwc refund contributors funds obtained unlawful solicitations order corporation pay civil penalty app pet cert separate segregated fund may completely controlled sponsoring corporation union whose officers may decide political candidates contributions fund spent assist fund must separate sponsoring union corporation sense must strict segregation monies corporation assets pipefitters see also buckley valeo one commentator stated license provided statutes respect enhanced loose use term member new york statute model act example offer meaningful definition member instead provide corporation articles bylaws may designate anybody nobody members may designate different classes members may freely specify rights corporation members classes members california act bit carefully drawn regard defining member essentially anyone entitled vote elections either corporation board directors certain fundamental corporate changes hansmann reforming nonprofit corporation law rev omitted assume parties courts ercc satisfies statutory requirements separate segregated fund nrwc corporation covered decision first national bank boston bellotti entirely consistent conclusion bellotti struck prohibition corporate expenditures contributions connection state referenda explicitly stated decision involve constitutionality laws prohibiting limiting corporate contributions political candidates committees means influencing candidate elections emphasis added addition following citation pipefitters automobile workers cio specifically pointed elections candidates public office unlike referenda issues general public interest may well threat real apparent corruption discussed text congress relied threat enacting also reject meritless nrwc claim commission actions prior conciliation misleading arbitrary constitute deprivation due process leave open consideration upon remand inter alia propriety commission imposition civil penalty respondent