On Wednesday, April 2, 2014, the United States Supreme Court struck down the aggregate, biennial contribution limits that restricted how much individuals could contribute to all candidates, PACs, and political party committees over the two-year election cycle. The case was brought by an Alabama businessman, Shaun McCutcheon, who challenged the overall limits as unconstitutional, and in a 5-4 decision, the majority of the Court agreed and held that the aggregate contribution limits violate the First Amendment and the United State Constitution.
For the 2013-2014 election cycle, the biennial aggregate contribution limits imposed an overall cap of $123,200 on the amount an individual could contribute to all federal candidates and political committees. Of that $123,200, only $48,600 could be contributed to federal candidates and only $74,600 could be contributed to PACs and party committees. Further, of the $74,600 that could be contributed to PACs and parties, only $48,600 could be contributed state and local party committee and PACs as opposed to national party committees. Importantly, the Court did not invalidate the base contribution limits, meaning individuals are still subject to a contribution limit of $2,600 per candidate per election ($5,200 combined for primary and general), $5,000 per year to a PACs, $10,000 per year to state and local party committees, and $32,400 per year to a national party committee. Moreover, individuals may still contribute unlimited amounts to Independent Expenditure-Only Committees often called "Super PACs."
In striking down the aggregate contribution limits, the Court emphasized and continued to uphold long-standing principles articulated in the seminal 1976 campaign finance opinion of Buckley v. Valeo, that the Government has a strong interest in combattingquid pro quo corruption or the appearance of corruption. However, the Court held that the aggregate contribution limits do not further that interest, and found the Government's argument that individuals will seek to circumvent the base contributions limits and will find ways to funnel "massive amounts of money to a candidate" through PACs or other entities, to be speculative given the laws and regulations that have been adopted since Buckley.
Notwithstanding the inflammatory rhetoric of self-proclaimed reform groups, it is unlikely that the Supreme Court's decision will lead to an influx of massive amounts of new money in federal elections. In fact, the Court noted that only about 650 individuals contributed the maximum amount to candidates, parties and PACs, in the last election cycle. Thus, from a practical standpoint, this decision will likely have little impact on the amounts most individuals choose to contribute to federal candidates and committees.