Francis R. “Frank” Valeo, 90, a former secretary of the U.S. Senate and, by chance, the defendant in Buckley v. Valeo, a U.S. Supreme Court decision that likened money to freedom of expression and set the course for decades of campaign finance debate, died April 9 at his home in Chevy Chase, Md. He had lung and kidney ailments.

A protege of Senator Mike Mansfield, the long-serving majority leader, Valeo was secretary of the Senate from 1966 to 1977. His administrative responsibilities came to include enforcement of campaign finance matters.

When James Buckley, then senator of New York, lent his name to a lawsuit protesting new congressional rules restricting the amount individuals could contribute to campaigns in 1974, Valeo became Defendant by virtue of his job. In the 1976 Buckley v. Valeo decision, the Supreme Court upheld public disclosure requirements, public financing of presidential elections, and the limits on individual contributions.

However, the court struck down on constitutional grounds – mainly citing First Amendment concerns – many of the provisions on spending limits, such as what an individual could give independently of a campaign or candidate.

Valeo told Roll Call that he had no interactions with Buckley during the legal ordeal but that he autographed a copy of the high court decision and sent it to the senator. In turn, Buckley sent Valeo a copy of the same decision inscribed to a ” ‘good loser,’ or something to that effect.”