How did Justice Breyer disagree with the majority’s definition of corruption?

In his dissenting opinion for McCutcheon v. Federal Election Commission, Justice Stephen Breyer challenged the majority’s narrow interpretation of corruption.1

While Chief Justice John G. Roberts, Jr. defined corruption strictly as quid pro quo—the direct exchange of an official act for money—Breyer argued that this definition was unrealistic and inconsistent with nearly all Supreme Court precedents since Buckley v. Valeo. Breyer contended that this limited construal failed to address the broader, grave problems of democratic legitimacy that campaign finance laws were originally intended to resolve.12

By restricting the government's interest solely to preventing bribery, Breyer argued that the majority’s opinion effectively "eviscerates" existing campaign finance laws. He maintained that the court should have considered how the absence of aggregate limits could lead to the circumvention of base limits, thereby allowing for the undue influence of money in politics, which he viewed as a fundamental threat to the integrity of the democratic process.13