• Aggregate limits on givings to a candidate or a party by an individual are unconstitutional
• Approaching unlimited contributions and expenditures
• Restricting the amount of money, a minor can contribute to a party or Canada is unconstitutional

Summary

FA forbids aggregate limits on the amount an individual may contribute during a two-year period to all federal candidates, parties, and political action committees combined.

Background (District Court)

The plaintiffs argue in this case that the biennial limits on political contributions are effectively limitations on expenditures, which are subject to a higher "strict scrutiny" standard of review.

McCutcheon and the other plaintiffs sued the Federal Election Commission, arguing that the aggregate limit violated the First Amendment by failing to serve a "cognizable government interest" and being prohibitively low.

The limits were periodically recalibrated to factor in inflation.

<aside> 💡 “The difference between contributions and expenditures is the difference between giving money to an entity and spending that money directly on advocacy. Contribution limits are subject to lower scrutiny because they primarily implicate the First Amendment rights of association, not expression, and contributors remain able to vindicate their associational interest in other ways."

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The court stated that the government may justify aggregate contribution limits as a means of preventing corruption or the appearance of corruption, or as a means of preventing circumvention of contribution limits imposed to further the government’s anti-corruption interest. The aggregate limits are able to prevent evasion of the base contribution limits.

The court rejected the plaintiffs' claims that the contribution limits were unconstitutionally low and overbroad, writing, "…it is not the judicial role to parse legislative judgment about what limits to impose."

The court noted that there are no “danger signs” that the contribution limits were not narrowly tailored to achieve the governmental interest in preventing corruption or the appearance of corruption.

The aggregate contribution limits affect what an individual may contribute directly to committees; those individuals still remain free to volunteer, join political associations and engage in independent expenditures.

Conclusion

<aside> 💡 FA’s protection of political contributions is not unlimited; Protecting against corruption or the appearance of corruption may necessitate restricting political contributions.

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<aside> 💡 Roberts went on to write, "Congress may target only a specific type of corruption—‘quid pro quo’ corruption . . . Spending large sums of money in connection with elections, but not in connection with an effort to control the exercise of an officeholder’s official duties, does not give rise to quid pro quo corruption. Nor does the possibility that an individual who spends large sums may garner ‘influence over or access to’ elected officials or political parties."

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"The aggregate limits on contributions do not further the only governmental interest this Court accepted as legitimate in Buckley. They instead intrude without justification on a citizen’s ability to exercise 'the most fundamental First Amendment activities.'"