U.S. Court of Appeals upholds per-election contribution limits

In Holmes v. FEC, the U.S. Court of Appeals for the District of Columbia Circuit unanimously rejected an argument that the Federal Election Campaign Act’s (FECA) base limits on individual contributions to candidates violated First Amendment rights. Plaintiffs Laura Holmes and Paul Jost argued that the federal law’s per-election contribution limits are unconstitutional, because the law allows individuals to contribute $2,600 to a candidate in both the primary and general elections but prohibits an individual to contribute $5,200 to a candidate in only the general election. The D.C. Circuit sitting en banc, per Judge Srinivasan, disagreed with the plaintiffs and cited the U.S. Supreme Court’s decision in Buckley v. Valeo, 424 U.S. 1 (1976), which rejected a constitutional challenge to per-election contribution limits. Judge Srinivasan noted that the Court “explained that, as long as a contribution limit is not so low as to prevent candidates from mounting effective campaigns, the judiciary would generally defer to Congress’s determination of the limit’s precise amount.” The D.C. Circuit used this logic to uphold Congress’s choice of the timeframe in which particular amounts of money may be contributed.