Summary
The Supreme Court granted certiorari, vacated the Ninth Circuit's judgment, and remanded for reconsideration of whether Alaska's $500 individual-to-candidate and individual-to-group campaign contribution limits violate the First Amendment. The per curiam opinion identified "danger signs" from *Randall v. Sorrell*: Alaska's limit is substantially lower than the $1,075 limit upheld in *Nixon v. Shrink Missouri Government PAC*, lower than comparable limits in most other states, and not adjusted for inflation. The Court did not reach the merits but directed the lower court to apply *Randall*'s framework, noting that Alaska's uniform $500 limit for all offices (including governor) is the most restrictive in the country. Justice Ginsburg's concurrence highlighted Alaska's unique vulnerability to corruption due to its small legislature and oil-dependent economy as a potential special justification.
Topics
Practice areas
Questions Presented
- Whether Alaska's individual-to-candidate and individual-to-group contribution limits violate the First Amendment, and whether the Ninth Circuit erred in failing to apply Randall v. Sorrell when analyzing the limits.
Holdings
- The Ninth Circuit's failure to apply Randall v. Sorrell was error; the case is remanded for reconsideration of whether Alaska's contribution limits are consistent with First Amendment precedent.
Key quotations
“contribution limits that are too low can . . . harm the electoral process by preventing challengers from mounting effective campaigns against incumbent officeholders, thereby reducing democratic accountability.” (at 3)
“Alaska's $500 individual-to-candidate contribution limit is substantially lower than the limits we have previously upheld.” (at 3)
“Alaska's $500 contribution limit is the most restrictive in the country in this regard.” (at 4)
“Alaska's $500 contribution limit is the same as it was 23 years ago, in 1996.” (at 5)
Factual background
Alaska law limits individual contributions to candidates for political office or election-oriented groups (other than political parties) to $500 per year. Petitioners Aaron Downing and Jim Crawford contributed the maximum amounts in 2015 but wanted to contribute more. They sued, contending the limits violate the First Amendment. The District Court and Ninth Circuit upheld the limits, with the Ninth Circuit applying a 'sufficiently important state interest' standard and finding the limits closely drawn to combat corruption.
Procedural history
The plaintiffs sued members of the Alaska Public Offices Commission, challenging Alaska's individual-to-candidate and individual-to-group contribution limits as violating the First Amendment. The District Court upheld the limits, and the Ninth Circuit affirmed. The Supreme Court granted certiorari, vacated the judgment, and remanded for further consideration in light of Randall v. Sorrell.
Remand instructions
For the Court of Appeals to revisit whether Alaska's contribution limits are consistent with our First Amendment precedents.