Why did the district court believe party committees could be used to direct money toward one candidate?

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In McCutcheon v. Federal Election Commission, the district court argued that aggregate contribution limits were necessary to prevent individuals from evading base limits on contributions to single candidates. The court outlined a hypothetical, multi-step process through which party committees could function as conduits to funnel large sums to a specific candidate:1

  • Step 1: An individual makes a single large contribution to a joint fundraising committee.1
  • Step 2: The committee distributes the funds among several party committees in accordance with base limits.1
  • Step 3: Because there are no limits on transfers between party committees of the same party, these committees transfer the received money to a single party committee.1
  • Step 4: That final committee uses the total transferred amount to cover the expenditures of a single candidate.1

While the court acknowledged that it might seem unlikely for multiple entities to serve as conduits, it reasoned that parties could implicitly agree to such a system, noting that the potential for a quid pro quo exchange does not depend on the number of steps involved in the transaction.1