In the 1981 case, Bread Political Action Committee et al. v. Federal Election Commission et al., the U.S Supreme Court upheld a provision of federal election law that limits political action committees (PACs) to contributing $5,000 per candidate in any given election. The court ruled against the Bread PAC and other plaintiffs who argued that this limit violated their First Amendment rights to free speech and association by restricting their ability to support candidates of their choice. The court found that while these contributions do implicate fundamental First Amendment interests, they also pose substantial risks for real or perceived corruption which justifies Congress's decision to impose limitations on them.

In the dissenting opinion for Bread Political Action Committee et al. v. Federal Election Commission et al., Justice Blackmun argued that the majority's decision was inconsistent with previous rulings and undermined First Amendment rights of political expression and association. He contended that limiting contributions to multicandidate political committees, such as PACs, did not serve a compelling governmental interest in preventing corruption or its appearance. Instead, he believed these limitations hindered citizens' ability to pool resources and promote collective political speech - an essential aspect of democratic participation. Furthermore, he criticized the majority for failing to apply strict scrutiny when evaluating restrictions on fundamental constitutional rights; instead they used a less rigorous standard which allowed them to uphold limits without demonstrating their necessity or effectiveness in achieving anti-corruption goals.