Thompson v. Hebdon

In Randall v. Sorrell, 548 U.S. 230 (2006), the Supreme Court established that political contribution limits that are unfairly low prevent challengers from launching effective campaigns and therefore negatively impact democratic accountability.

Petitioners are Alaska residents who made the maximum political contributions permitted under Alaska law. Wanting to contribute more, they filed suit against Respondent, arguing that Alaska’s contribution limits violate the First Amendment. The district court upheld the limits. The Ninth Circuit affirmed, analyzing whether the limits advanced a sufficiently important state interest and were narrowly tailored for that purpose. The Ninth Circuit pointed to the Supreme Court’s decisions in Citizens United v. Federal Election Comm’n, 558 U.S. 310 (2010), and McCutcheon v. Federal Election Comm’n, 572 U.S. 185 (2014), which narrowed the type of state interest that would justify this kind of intrusion to “actual quid pro quo corruption or its appearance.” The Supreme Court vacated and remanded for the Ninth Circuit to consider Randall v. Sorrell, 548 U.S. 230 (2006), which invalidated a Vermont law that limited individual contributions of $400 and lower. In Randall the Court held that unfairly low limits prevent challengers from launching effective campaigns against their opponents and incumbent officeholders. The Court identified several danger signs which Alaska’s contribution limits share. Alaska’s individual-to-candidate and individual-to-group contribution limits are significantly lower than others previously upheld and Alaska’s limits have not been adjusted for inflation. VACATED and REMANDED.