Campaign Limits: Will the courts punish those municipal elections?

A lot of the press has been focused on how certain statewide and state legislators will possible have to return some of their campaign contributions. Again I will like to know if further rulings from the Missouri Supreme Court on this issue will take into account the municipal elections that already took place this spring? There are certain city council and school board elections that have run it's course and these campaigns do not have money in their accounts to refund excess contributions. I do agree that those political offices that are to be determined in 2008 should refund excess monies. The reason being is that not everyone has entered the races and technically have till the end of March to run. Those folks will not have the chance to solicit uncapped contributions and therefore those who started the fundraising during the unlimited fundraising period would have an unfair advantage. On the bright side, Matt Blunt will have to refund tons of money. On the not so bright side, Jay Nixon will have to pay back a good chuck of money as well.