Michigan Education Ass'n v. Secretary of State

I respectfully dissent. The majority posits the issue before us as whether under the *490Michigan Campaign Finance Act (MCFA) “advance reimbursement for the costs of a payroll deduction system prevents what is otherwise an illegal expenditure from ever becoming an ‘expenditure.’ ”1 The majority concludes it does not. I disagree. Under the particular, and peculiar, definitions contained in the self-contained looking-glass2 world of the MCFA, the costs of such payroll deduction systems are not “expenditures” at all. Thus, the trial court reached the right result, although for the wrong reason. I…