Thompson v. Hebdon
Headline: Court sends Alaska’s $500 individual campaign contribution limits back to the appeals court for fresh review, raising the possibility that Alaska donors could face fewer restrictions if limits fail constitutional scrutiny.
Holding: The Court vacated the appeals court’s judgment and remanded for reconsideration whether Alaska’s $500 individual-to-candidate and group contribution limits comply with the First Amendment under Randall.
- Could lead appeals court to strike down or adjust Alaska’s $500 donation cap.
- May allow Alaskans to give larger contributions if limits are invalidated.
- Prompts states to consider indexing or justifying low contribution limits.
Summary
Background
Aaron Downing and Jim Crawford, two Alaska residents, gave the maximum allowed donations under Alaska law but wanted to give more. They sued officials who enforce Alaska’s campaign rules, arguing the $500 annual limit on individual gifts to candidates and to election-focused groups violates the First Amendment. A federal trial court and the Ninth Circuit both upheld the limits, with the Ninth Circuit relying on its own precedents that allow contribution limits to stand so long as they further a legitimate anti-corruption interest.
Reasoning
The key question became whether Alaska’s low, uniform $500 limit is consistent with this Court’s earlier decisions, especially the Court’s 2006 ruling in Randall v. Sorrell. The Court granted review, vacated the Ninth Circuit’s judgment, and sent the case back for reconsideration so the appeals court can evaluate Alaska’s law under Randall. The opinion highlights several concerns: Alaska’s limit is much lower than limits the Court previously upheld, it applies to all offices including governor, and it has not been adjusted for inflation since 1996.
Real world impact
The Court’s order does not change the law yet. Instead, it requires the appeals court to reconsider whether Alaska’s limits are constitutional. If the appeals court finds the limits invalid, Alaskans could be allowed to give more to candidates or groups, or the State could respond by explaining special reasons for its low cap. The ultimate outcome will affect donors, candidates, and how campaigns are funded in Alaska.
Dissents or concurrances
Justice Ginsburg agreed with the remand and noted Alaska differs from Vermont in important ways, including party limits and Alaska’s small legislature and heavy reliance on oil and gas revenue, which might justify closer scrutiny.
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