The General Counsel's Office Files are an important resource for examining the legal issues involved in the operation of a presidential campaign committee. In addition the collection extensively documents the development of the Federal Election Commission, its role in regulating campaign finances, and PFC receipts and expenditures. Smaller, but important, segments concern aspects of PFC operations beyond the work of the legal staff, including notes on some high-level meetings and weekly reports of the Political Office field coordinators.
The General Counsel was the legal adviser to the President Ford Committee. His office, consisting of two lawyers and their secretaries, played an extremely important role in the 1976 presidential campaign.
The major differences between the PFC General Counsel's role and the role of lawyers in previous presidential campaigns were caused by the passage of the Federal Election Campaign Act Amendments of 1974. This legislation, signed into law by President Ford on October 15, 1974, established the first spending limits ever for candidates in presidential primary and general elections, provided for disclosure and reporting of campaign contributions and expenditures, introduced public financing for general election campaigns and matching funds to cover part of the costs of primary campaigns, and created a Federal Election Commission (FEC) to develop specific regulations implementing the law and enforce its provisions.
Because of delays in the appointment and confirmation of FEC members, the Commission did not begin its work until just before initial efforts to organize the PFC began. This meant that the PFC, like several other 1976 campaign committees, had to begin the process of running a campaign while frequently asking the FEC for guidance on procedures or filing complaints about possible violations by other campaign committees. The PFC General Counsel and his assistant handled these interactions with the FEC, while also working on more traditional campaign committee attorney tasks such as lawsuits, delegate challenges, contracts with consulting firms and staff members, coordinating the work of the PFC state legal counsels, and ballot security.
During the early months of the Ford campaign, Washington lawyer Dean Burch and members of his law firm handled much of the legal work under contract, but in September 1975, when the work became full-time, the PFC hired attorney Robert P. Visser as General Counsel. After a short time he added Tim Ryan as his assistant. Unlike most PFC offices, there was no staff turnover during the campaign, so Visser and Ryan handled the PFC's legal work through election day and even into the early part of 1977.
The files of the General Counsel's Office comprise a key resource for studying the changes in campaigning for President deriving from the implementation of the new campaign laws. The files also contain extensive files on the development of the FEC and its rules and regulations, including case files on each FEC meeting (usually attended by Visser or Ryan whose handwritten notes on the meeting or memoranda to the record often appear in the file). The General Counsel's Office Files also include significant materials on the Supreme Court decision in January 1976 which invalidated portions of the Federal Election Campaign Act and the development of the 1976 amendments to that law.
Visser or Ryan usually attended meetings of the Committee's Executive Committee, Advisory Committee, and Convention Cordinating Group. Although their material on those meetings is not extensive, it often includes either handwritten or typed notes on the discussions or memoranda listing assignments made to various staff members.
Materials on various lawsuits, contracts and other legal work conducted by the office also appears.
Related Materials (as of June 1990):
The files of Philip Buchen, Counsel to the President, contain materials on a number of campaign-related legal questions, including the Federal Election Campaign Act Amendments of 1974 and 1976 and White House interactions with the Federal Election Commission concerning proposed rulings and regulations. The staff files of John Marsh, Edward Schmults, and Rogers Morton also contain related materials, especially on the 1976 campaign law amendments. The White House Central Files Subject File contains material in categories FG 387 (Federal Election Commission) and PL (Political Affairs).