Florida Statutes
Fla. Stat. § 106.34 (2025)
Expenditure limits.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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106.34 Expenditure limits.—
(1) Any candidate for Governor and Lieutenant Governor or Cabinet officer who requests contributions from the 1Election Campaign Financing Trust Fund shall limit his or her total expenditures as follows:
(a) Governor and Lieutenant Governor: $2.00 for each Florida-registered voter.
(b) Cabinet officer: $1.00 for each Florida-registered voter.
(2) The expenditure limit for any candidate with primary election opposition only shall be 60 percent of the limit provided in subsection (1).
(3) For purposes of this section, “Florida-registered voter” means a voter who is registered to vote in Florida as of June 30 of each odd-numbered year. The Division of Elections shall certify the total number of Florida-registered voters no later than July 31 of each odd-numbered year. Such total number shall be calculated by adding the number of registered voters in each county as of June 30 in the year of the certification date.
(4) For the purposes of this section, the term “expenditure” does not include the payment of compensation for legal and accounting services rendered on behalf of a candidate.
History.—s. 1, ch. 86-276; s. 41, ch. 90-315; s. 21, ch. 91-107; s. 654, ch. 95-147; s. 48, ch. 2005-278; s. 7, ch. 2018-110; ss. 1, 6, ch. 2024-116.
1Note.—The trust fund expired, effective November 4, 1996, by operation of s. 19(f), Art. III of the State Constitution.
Notes of Decisions
Cited in 4
cases, 1994–2010 · leading case: Smith v. Crawford, 645 So. 2d 513 (Fla. 1st DCA 1994).
Smith v. Crawford, 645 So. 2d 513 (Fla. 1st DCA 1994). “§ 106.34, Fla. Stat. (1993). Upon withdrawal from the race for Governor, Jim Smith immediately ceased receiving any further contributions and took steps to close his campaign accounts, including earmarking for payment to the state of surplus funds in the campaign account as…”
Scott v. Roberts, 612 F.3d 1279 (11th Cir. 2010). “That system also provides participating candidates like McCollum with a subsidy when a nonparticipating opponent spends in excess of for each registered Florida voter, which for this election means almost million.”
Repub. Party of Florida v. Smith, 638 So. 2d 26 (Fla. 1994). “These sections adequately specify, control, and limit the funds transferred.”
Richard L. Scott v. Dawn K. Roberts (11th Cir. 2010). “Fla. Stat. §§ 106.34 , 106.355. On July 7, as his campaign expenditures were rapidly approaching the million threshold, Scott filed a complaint in the district court and asked the court to enjoin preliminarily the operation of the excess spending subsidy.”
— 106.34(1)(b) — 1 case
Smith v. Crawford, 645 So. 2d 513 (Fla. 1st DCA 1994). “§ 106.34, Fla. Stat. (1993). Upon withdrawal from the race for Governor, Jim Smith immediately ceased receiving any further contributions and took steps to close his campaign accounts, including earmarking for payment to the state of surplus funds in the campaign account as…”
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