McCutcheon v. F.E.C.

Brief Fact Summary.

The statute that restricts how much money a donor may contribute to a particular candidate or committee and how much money a donor may contribute in total to all candidates or committees was challenged. The Court already held that the statute may impose base limits because they sere the permissible objective of combating corruption.

Synopsis of Rule of Law.

The only legitimate governmental interest for restricting campaign finances is to prevent corruption or the appearance of corruption.

Facts.

The statute at issue restricts how much money a donor may contribute to a particular candidate or committee and how much money a donor may contribute in total to all candidates or committees. The Government contends that the aggregate limits serve the objective of combating corruption by preventing circumvention of the base limits.

Issue.

Does the statute that restricts how much money a donor may contribute in total to all candidates or committees violate the Constitution?

Held.

Yes, the aggregate limits do little, if anything, to address the Government’s concern on potential circumvention of the base limits, while seriously restricting participation in the democratic process. The aggregate limits deny the individual all ability to exercise his expressive and associational rights by contributing to someone who will advocate for his policy preferences. Thus, the aggregate limits are invalid under the First Amendment.

Dissent.

Justice Breyer

There is no substantial mismatch between Congress’ legitimate objective and the means selected to achieve it. Moreover, the plurality does not show that its hypothetical alternatives could effectively replace aggregate contribution limits. Determining whether anti-corruption objectives justify a particular set of contribution limits requires answering empirically based questions. These kinds of questions are questions that Congress is far better suited to resolve than are judges.

Discussion.

To require one person to contribute at lower levels than others because he wants to support more candidates is to impose a special burden on broader participation in the democratic process. The aggregate limits, however, do not serve the function and interest in any meaningful way. The Government’s fear that an individual might contribute massive amounts of money to a particular candidate through the use of unearmarked contributions is far too speculative. Moreover, there are multiple alternatives Congress could adopt to serve its anti-circumvention interest, while avoiding unnecessary abridgment of the First Amendment rights. The statute impermissibly restricts participation in democratic process violating the First Amendment.