McCutcheon v. Federal Election Comm'n
The Supreme Court struck down the overall cap on how much money one person can give in total to federal candidates and political committees during an election cycle, ruling it violates the First Amendment.
The decision leaves the per-candidate and per-committee contribution limits in place, but it means wealthy donors can now spread their money across many more candidates and party committees than before, reshaping how much individual donors can put into the political system overall.
“The Government may no more restrict how many candidates or causes a donor may support than it may tell a newspaper how many candidates it may endorse.”
The majority explains why capping how many candidates a donor may support burdens core First Amendment rights.
How it got here: A three-judge federal district court denied a preliminary injunction and dismissed the suit, upholding the aggregate limits; McCutcheon and the RNC appealed directly to the Supreme Court.
The Case in Depth
What happened
Shaun McCutcheon, an Alabama businessman, wanted to contribute to more federal candidates and political committees than the overall aggregate limit allowed, even though each individual contribution stayed within the base per-candidate and per-committee limits. He and the Republican National Committee wanted to keep making these contributions in future elections but were blocked by the total dollar cap Congress set on giving across all federal candidates and committees combined.
The question before the Court
Can the federal government cap the total amount a person may give across all federal candidates and party committees combined, even if each individual gift stays within the normal contribution limits?
Why it matters
Wealthy donors can now give the maximum allowed amount to far more candidates, parties, and committees than the old aggregate cap permitted, potentially channeling millions of dollars into a single election cycle. Political parties and campaign committees gain a new pool of large-check donors to court, while critics worry this expands the influence of a small number of very wealthy contributors.
What changes now
The case is sent back to the district court for further proceedings consistent with the ruling, though the core legal question -- that the aggregate contribution limits are unconstitutional -- has been finally decided. The base, per-candidate and per-committee contribution limits remain fully in force and are not affected by this ruling. Congress or the Federal Election Commission could adopt narrower anti-circumvention measures, such as tighter transfer or earmarking rules, if they choose to address the concerns raised in the case.
What this does not decide
This decision does not touch the base limits on how much a donor may give to any single candidate, party committee, or PAC -- those remain fully in effect. The Court also did not revisit or overturn Buckley v. Valeo's basic framework distinguishing contribution limits from spending limits, and it did not decide whether any specific alternative anti-circumvention rule would be constitutional.
Concurrences and dissents
Concurrence — Justice Thomas
Justice Thomas agreed the aggregate limits are unconstitutional but would have gone further and overruled Buckley v. Valeo entirely, applying strict scrutiny to all contribution limits, which he believes the aggregate limits would clearly fail. He argues Buckley's distinction between contributions and expenditures was flawed from the start and has only grown weaker over time, since both are simply forms of political speech.
Dissent — Justice Breyer
Justice Breyer argued the majority defines corruption too narrowly, ignoring the broader interest in preventing undue influence and access that this Court's precedents, especially McConnell v. FEC, have long recognized. He contended that without aggregate limits, donors and parties can funnel millions of dollars to individual candidates through joint fundraising committees and networks of PACs, and that the majority wrongly decided factual questions about circumvention without a trial record. He would have upheld the aggregate limits as constitutional.
How the Court got there
The legal reasoning, step by step
- The Court applied the 'closely drawn' test from Buckley v. Valeo, which asks whether a contribution limit serves a sufficiently important government interest through means that avoid unnecessary abridgment of political-association rights, without needing to decide whether an even stricter test should apply.
- The Court found that Congress's only legitimate reason for limiting contributions is preventing quid pro quo corruption -- a direct exchange of money for a specific official act -- or its appearance, not simply reducing the general influence or access wealthy donors might have with officeholders.
- Because the base, per-candidate and per-committee limits already set the threshold below which Congress believes contributions pose no meaningful corruption risk, the aggregate limit could only be justified as a tool to stop donors from evading those base limits by routing money through intermediaries.
- Reviewing current anti-circumvention laws -- including limits on giving to political committees, a rule against creating multiple affiliated committees, and detailed anti-earmarking regulations adopted since Buckley -- the Court concluded these safeguards make the kind of circumvention Buckley worried about in 1976 highly unlikely today.
- The Court also found the aggregate limit poorly tailored because it imposes a blanket ban on all further giving rather than targeting the specific transfers that could actually enable circumvention, when narrower tools like transfer restrictions or tighter earmarking rules could address that risk with less burden on speech.
- Having found no meaningful anti-circumvention benefit and a mismatch between the total ban and the government's stated interest, the Court concluded the aggregate limits fail even under the more lenient contribution-limit standard of review.
Doctrinal impact
Cases affected by this decision
Limits Buckley v. Valeo (424 U. S. 1)
The Court declined to follow Buckley's brief, three-sentence approval of the original aggregate contribution limit.
Distinguishes McConnell v. Federal Election Comm'n (540 U. S. 93)
The Court said its ruling does not overrule McConnell's separate holding upholding restrictions on 'soft money' contributions.