In a case brought by an association seeking the recall of a city councilman arguing that San Diego's contribution limit is unconstitutional as applied to the signature-gathering phase of a recall election, a judgment against the association is vacated where the district court's preliminary decision to apply the less rigorous scrutiny of Buckley v. Valeo, 424 U.S. 1 (1976), was correct, however, the court erred by deciding that the city had a sufficient interest justifying the application of its contribution limits to the signature-gathering phase of a recall election, without requiring further evidentiary development.