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12-536 McCUTCHEON V. FEDERAL ELECTION COMMISSION DECISION BELOW: 2012 WL 4466482 JURISDICTION NOTED 2/19/2013 QUESTION PRESENTED: Federal law imposes two types of limits on individual political contributions. Base limits restrict the amount an individual may contribute to a candidate committee ($2,500 per election), a national-party committee ($30,800 per calendar year), a state, local, and district party committee ($10,000 per calendar year (combined limit)), and a political-action committee ("PAC") ($5,000 per calendar year). 2 U.S.C. 441a(a)(1) (current limits provided). Biennial limits restrict the aggregate amount an individual may contribute biennially as follows: $46,200 to candidate committees; $70,800 to all other committees, of which no more than $46,200 may go to non-national-party committees (e.g., state parties and PACs). 2 U.S.C. 441a(a)(3) (current limits provided) (see Appendix at 20a (text of statute)). Appellants present five questions: 1. Whether the biennial limit on contributions to non-candidate committees, 2 U.S.C. 441a(a) (3)(B), is unconstitutional for lacking a constitutionally cognizable interest as applied to contributions to national-party committees. 2. Whether the biennial limits on contributions to non-candidate committees, 2 U.S.C. 441a(a) (3)(B), are unconstitutional facially for lacking a constitutionally cognizable interest. 3. Whether the biennial limits on contributions to non-candidate committees are unconstitutionally too low, as applied and facially. 4. Whether the biennial limit on contributions to candidate committees, 2 U.S. C. 441a(a)(3) (A), is unconstitutional for lacking a constitutionally cognizable interest. 5. Whether the biennial limit on contributions to candidate committees, 2 U.S.C. 441a(a)(3) (A), is unconstitutionally too low. LOWER COURT CASE NUMBER: 12cv1034
In the 2013 case McCutcheon v. Federal Election Commission (FEC), the U.S. Supreme Court ruled in a 5-4 decision that certain limits on campaign contributions by individuals were unconstitutional, violating First Amendment rights to free speech. The court struck down aggregate limits on how much an individual can donate to all candidates, parties and political action committees combined in a two-year election cycle while maintaining base limit donations to single candidates or committees. Prior to this ruling, federal law had set both types of restrictions: base limits restricting what one person may give to a specific candidate or committee and aggregate limits capping total contributions from one donor across multiple recipients within an election cycle. Critics argued that removing these caps would lead to corruption; however, supporters claimed it was necessary for free speech.
In the dissenting opinion for McCutcheon v. FEC, Justice Breyer argued that the majority's decision to strike down aggregate contribution limits would lead to a significant increase in both actual corruption and the appearance of corruption within American politics. He contended that these limits were essential tools for preventing wealthy individuals from using large campaign contributions to gain undue influence over elected officials. Furthermore, he disagreed with the majority's narrow definition of corruption as only encompassing direct quid pro quo exchanges between donors and politicians, asserting instead that it should also include more subtle forms of improper influence and access-buying. Lastly, Justice Breyer criticized his colleagues' assertion that First Amendment concerns necessitated their ruling; he maintained that protecting democratic integrity was just as important a constitutional value as free speech.