- Date:
- April 2, 2014
- Location:
- United States
McCutcheon v. Federal Election Commission
-
What was the McCutcheon v. Federal Election Commission case about?
The McCutcheon v. Federal Election Commission case challenged the aggregate limits on individual contributions to multiple federal candidates, political party committees, and noncandidate political action committees (PACs) under the Federal Election Campaign Act (FECA). Shaun McCutcheon, an Alabama businessman, and the Republican National Committee (RNC) argued these limits infringed on First Amendment freedoms.
In 2014, the Supreme Court struck down (5–4) FECA's aggregate limits, deeming them a violation of freedom of association and speech. The ruling retained FECA’s base limits on individual contributions to single candidates and committees. Conservatives hailed the decision as a First Amendment victory, while liberals feared increased influence of money in politics, similar to the Citizens United v. Federal Election Commission ruling.
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Who were the people and organizations involved in this case?
McCutcheon v. Federal Election Commission involved several people and organizations:
- Shaun McCutcheon: An Alabama businessman who wanted to donate more than the aggregate limit to multiple candidates, party committees, and PACs.
- Republican National Committee (RNC): The RNC manages the Republican Party's affairs and joined McCutcheon in challenging FECA's aggregate limits.
- Federal Election Commission (FEC): The defendant in the case, the FEC is the independent regulatory agency responsible for enforcing campaign finance laws in the United States.
- U.S. Supreme Court: Ultimately decided the case, striking down FECA's aggregate limits on individual contributions.
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What law or rules were being challenged in this case?
In McCutcheon v. Federal Election Commission, Shaun McCutcheon and the Republican National Committee (RNC) challenged the aggregate limits on individual contributions to multiple federal candidates, political party committees, and noncandidate political action committees (PACs) as a violation of the First Amendment.
At the time, the Federal Election Campaign Act (FECA) imposed aggregate limits of $46,200 to all candidates and $70,800 to all party committees and noncandidate PACs for two-year election cycles. McCutcheon argued these limits were no longer justified to prevent corruption, as the base limits on contributions to single candidates and restrictions on contributions to party committees and PACs made indirect transfers of large sums to candidates difficult.
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Why did Shaun McCutcheon believe campaign donation limits were unfair?
Shaun McCutcheon believed that the aggregate limits on campaign donations imposed by the Federal Election Campaign Act (FECA) infringed upon First Amendment freedoms. He argued these limits were not justified by the government's interest in preventing corruption, especially since FECA amendments had already restricted individual contributions to party committees and PACs, and limited contributions from these entities to candidates. McCutcheon contended that the existing base limits on contributions to single candidates made aggregate limits unnecessary to prevent circumvention.
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How did the Supreme Court rule on this case and what was their reasoning?
In McCutcheon v. Federal Election Commission, the Supreme Court ruled (5–4) that the Federal Election Campaign Act's (FECA) aggregate limits on individual contributions to multiple federal candidates, political party committees, and noncandidate political action committees (PACs) violated the First Amendment.
The Court held that these limits infringed upon freedom of association and speech guarantees. While FECA's limits on individual contributions to single candidates and political committees remained, the majority opinion, authored by Chief Justice Roberts, defined corruption as limited to quid pro quo exchanges, arguing that aggregate limits weren't necessary to prevent circumvention of base limits.
Dissenting, Justice Breyer contended that the decision weakened campaign finance laws and that the definition of corruption was unrealistic and unsupported by precedent.
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What impact did this Supreme Court decision have on campaign finance laws in the United States?
The Supreme Court's decision in McCutcheon v. Federal Election Commission on April 2, 2014, had a notable impact on campaign finance laws in the United States. The ruling struck down provisions of the Federal Election Campaign Act (FECA) that imposed aggregate limits on individual contributions to multiple federal candidates, party committees, and noncandidate political action committees (PACs).
The court held that these aggregate limits violated the First Amendment's guarantees of freedom of association and speech. While the ruling eliminated aggregate limits, it left in place the base limits on contributions to single candidates and political committees.
Many liberals and campaign finance reform proponents predicted that the McCutcheon decision would increase the influence of money in American politics, similar to the court's 2010 ruling in Citizens United v. Federal Election Commission.
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McCutcheon v. Federal Election Commission, legal case in which the U.S. Supreme Court on April 2, 2014, struck down (5–4) provisions of the Federal Election Campaign Act (FECA; 1971)—as amended by the FECA Amendments (1974; 1976) and the Bipartisan Campaign Reform Act (BCRA; 2002)—that had imposed aggregate limits on monetary contributions by individuals to multiple federal candidates, political party committees, and noncandidate political action committees (PACs). (The limit on contributions to PACs did not apply to so-called Super PACs, which do not give money to candidates and whose spending is not coordinated with any political campaign.) The court held these limits to be a violation of the First Amendment’s guarantees of freedom of association and freedom of speech. The ruling left in place FECA’s limits on contributions by individuals to single candidates and political committees, the so-called “base limits,” which were not at issue in the case.
While many conservative court watchers, including some free-speech advocates, celebrated the decision as a victory for the First Amendment, most liberals, including proponents of campaign finance reform, predicted that it would increase the pernicious influence of money in American politics—as did, in their opinion, the court’s 2010 ruling in Citizens United v. Federal Election Commission.
Background
McCutcheon v. Federal Election Commission arose in June 2012 when Shaun McCutcheon, an Alabama businessman, and the Republican National Committee (RNC), which manages the affairs of the national Republican Party, challenged FECA’s aggregate limits in U.S. district court. At that time, FECA’s aggregate limits for two-year election cycles—the period beginning on January 1 of an odd-numbered year and ending on December 31 of the following even-numbered year—were $46,200 to all candidates and $70,800 to all party committees and noncandidate PACs. FECA also specified base limits of $2,500 per election to a single candidate (or $5,000 to a single candidate for both the primary and the general elections), $30,800 per year to a national party committee, and $5,000 per year to a noncandidate PAC. Beginning in 2011, McCutcheon made contributions (all within the base limits) of more than $33,000 to several candidates and of more than $32,000 to national party committees and noncandidate PACs. During the remainder of the 2011–12 election cycle, however, he wished to contribute $1,776 to each of 12 additional candidates and $25,000 to each of three national-party committees, as well as unspecified amounts to other party committees and noncandidate PACs, which would have raised his aggregate totals to more than $49,000 for all candidates and to more than $107,000 for all party committees and noncandidate PACs, in violation of the aggregate limits. In addition, McCutcheon wished to contribute a total of $60,000 to candidates and $75,000 to three national-party committees during 2013–14, which would put him over the aggregate limits for that election cycle.
In June 2012 McCutcheon filed suit against the Federal Election Commission (FEC) in federal district court, arguing that the infringements of First Amendment freedoms created by FECA’s aggregate limits were no longer justified by the government’s compelling interest in preventing “the reality and appearance of corruption,” as the Supreme Court described the purpose of FECA’s base and aggregate limits when it upheld both in Buckley v. Valeo (1976). In particular, McCutcheon urged, aggregate limits were not necessary to prevent circumvention of the base limit on contributions to single candidates—by, among other strategies, funneling large contributions through party committees and PACs—because FECA amendments and regulations implemented since 1976 had imposed, among other restrictions, base limits on contributions from individuals to party committees and PACs and limits on contributions from party committees and PACs to single candidates, making indirect transfers of large sums to candidates difficult, if not impossible.
The district court rejected this argument, holding that aggregate limits remained necessary because, without them, an individual could (at least hypothetically) evade the base limit on contributions to single candidates in ways not contemplated by the Buckley court, including by: (1) making a single large contribution to a joint fund-raising committee, which would (2) distribute the money among several party committees (in accordance with the base limits), which would in turn (3) transfer the money received to a single party committee (there being no limits on transfers of money between party committees of the same party), which would (4) use all of the transferred money to cover the expenditures of a single candidate. Although “it may seem unlikely that so many separate entities would willingly serve as conduits for a single contributor’s interests,” the court reasoned, “it is not hard to imagine a situation where the parties implicitly agree to such a system…and there is no reason to think the quid pro quo of an exchange depends on the number of steps in the transaction.” McCutcheon appealed the district court’s decision directly to the Supreme Court, and oral arguments were heard on October 8, 2013.
