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McCutcheon v. Federal Election Commission

Supreme Court of the United States · 2014 · Constitutional Law

Constitutional LawFirst AmendmentCampaign FinanceFirst Amendmentcampaign contributionsaggregate limitsbase limitsquid pro quo corruption

Facts

FECA, as amended by BCRA, imposed base limits on how much an individual could contribute to any particular candidate or committee, and separate aggregate limits on how much an individual could contribute in total to all candidates and committees during a two-year election cycle. Shaun McCutcheon contributed to multiple federal candidates and political committees in amounts within the base limits, but alleged that the aggregate limits prevented him from contributing to additional candidates and committees he wished to support. The RNC alleged that it wanted to receive contributions otherwise permitted by the base limits but barred by the aggregate limits. The Government defended the aggregate limits as necessary to prevent circumvention of the valid base limits.

Issue

Whether FECA's aggregate limits on an individual's total contributions to all federal candidates and political committees violate the First Amendment. More specifically, the question was whether those aggregate limits are sufficiently tailored to the permissible governmental interest in preventing quid pro quo corruption or its appearance, principally by preventing circumvention of the base limits.

Rule

The only legitimate governmental interest for restricting campaign contributions is preventing quid pro quo corruption or its appearance. Contribution limits must be closely drawn to avoid unnecessary abridgment of First Amendment rights, and aggregate contribution limits are unconstitutional when they do little, if anything, to prevent circumvention of valid base limits while substantially restricting a donor's ability to support multiple candidates and committees.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress leaves in place per-candidate contribution caps for federal races but adds a rule that no individual may contribute to more than 12 federal candidates during a two-year election cycle. Elena Park of Seattle wants to give the maximum lawful amount to 18 candidates from different states who share her views on climate policy, but the new rule bars contributions to the last six.

If Elena challenges the 12-candidate cap under the First Amendment, which argument best supports striking it down?

Explanation. The majority held that aggregate limits burden First Amendment rights by restricting how many candidates and committees a donor may support. The only permissible interest is preventing quid pro quo corruption or its appearance, not reducing money in politics or limiting influence and access. Once base limits remain in place, the government must show that an aggregate cap meaningfully prevents circumvention of those valid base limits. A flat limit on the number of candidates supported is not closely drawn if it broadly bans additional lawful contributions without a demonstrated anticircumvention fit.