By Michael Phillips | People’s Law Review

McCutcheon v. Federal Election Commission (572 U.S. 185, decided April 2, 2014) is a landmark U.S. Supreme Court decision that reshaped campaign-finance law by striking down aggregate contribution limits in federal elections. In a closely divided 5–4 ruling, the Court held that overall caps on how much an individual may contribute across all federal candidates and political committees violated the First Amendment’s protections for free speech and political association.

The decision left intact per-recipient contribution limits but eliminated the ceiling on total political giving, fundamentally altering how money flows through modern campaigns.

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Background: What Was at Stake

Federal campaign-finance law, primarily the Federal Election Campaign Act as amended by the Bipartisan Campaign Reform Act, imposed two distinct limits on individual contributions:

1. Base (Per-Recipient) Limits
   These cap how much one person may give to a single candidate, party committee, or political action committee (PAC).
   • In 2014, the limit was $2,600 per candidate per election (adjusted periodically for inflation).
2. Aggregate Limits
   These capped the total amount an individual could contribute across all federal recipients during a two-year election cycle.
   • For the 2011–2012 cycle, individuals could give:
     • $48,600 total to federal candidates, and
     • $74,600 total to parties and PACs,
     • for a combined ceiling of $123,200.

Shaun McCutcheon, an Alabama businessman, and the Republican National Committee challenged the aggregate limits. McCutcheon had legally maxed out contributions to 16 federal candidates but wished to support additional candidates and committees. He argued that the aggregate cap prevented him from fully participating in the political process, even though each individual contribution complied with base limits.

The federal government defended the aggregate limits as necessary to prevent circumvention of per-candidate caps and to reduce the risk—or appearance—of quid pro quo corruption.

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The Supreme Court’s Ruling

Plurality Opinion

Chief Justice John Roberts, joined by Justices Scalia, Kennedy, and Alito, concluded that aggregate limits were unconstitutional.

Key points from the plurality:

• Contribution limits are evaluated under the “closely drawn” scrutiny standard established in Buckley v. Valeo, but aggregate caps failed even that lower bar.
• Aggregate limits were not a “modest restraint” on speech; they restricted how many candidates or causes a donor could support, burdening core First Amendment activity.
• Preventing quid pro quo corruption is a legitimate governmental interest, but aggregate limits did not meaningfully advance that goal beyond existing base limits.
• Concerns about circumvention were speculative and could be addressed through narrower tools such as earmarking rules, disclosure requirements, and targeted transfer restrictions.

Roberts memorably emphasized that:

“Ingratiation and access… are not corruption. They embody a central feature of democracy.”

Concurrence

Justice Clarence Thomas agreed that the aggregate limits were unconstitutional but went further, arguing that all contribution limits should be subject to strict scrutiny. He questioned the long-standing distinction between contributions and expenditures established in Buckley.

Dissent

Justice Stephen Breyer, joined by Justices Ginsburg, Sotomayor, and Kagan, warned that removing aggregate limits would enable wealthy donors to exert disproportionate influence by spreading maximum contributions across many recipients. The dissent viewed aggregate limits as a reasonable anticircumvention safeguard essential to preserving democratic equality.

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What the Court Left in Place

Importantly, McCutcheon did not eliminate contribution limits altogether.

• Per-recipient base limits remain valid.
  Donors still may not exceed the legal maximum to any single candidate or committee.
• There is no right to give unlimited sums to one candidate, even after McCutcheon.

For the 2025–2026 cycle, for example, the federal per-candidate limit is $3,300 per election, adjusted for inflation.

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Key Impacts Nationwide

The immediate effect of McCutcheon was the elimination of the federal two-year aggregate cap. High-dollar donors may now give the maximum allowed amount to an unlimited number of candidates, parties, and PACs.

This shift has:

• Increased the importance of joint fundraising committees, which bundle contributions efficiently.
• Amplified the role of mega-donors and national donor networks.
• Contributed to rising overall fundraising totals and intensified competition for high-net-worth contributors.
• Further aligned campaign-finance law with the deregulatory trajectory that began with Citizens United v. Federal Election Commission, though McCutcheon focused on direct contributions rather than independent expenditures.

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State-Level Effects: The Maryland Example

The ruling’s influence extended beyond federal elections.

Many states—including Maryland—had their own aggregate contribution limits. After McCutcheon, Maryland advised that it would no longer enforce its state aggregate cap, which previously limited the total amount an individual could contribute across all state recipients.

Today in Maryland:

• Donors may give up to $6,000 per recipient per four-year election cycle.
• There is no overall ceiling on total contributions across candidates, parties, or PACs.

This change has had practical consequences:

• Candidates and parties with access to national donor networks can now raise larger sums by expanding the number of recipients.
• Out-of-state money flows more freely into Maryland races without a cumulative cap.
• The system preserves formal equality at the per-recipient level while allowing substantial disparities in total political influence.

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Why McCutcheon Still Matters

At its core, McCutcheon reflects a constitutional choice: prioritizing individual donors’ rights to support multiple candidates and causes over broad government efforts to limit total political influence from any one person.

The decision preserved per-recipient safeguards while rejecting aggregate caps as too blunt and too speech-restrictive. More than a decade later, it continues to shape campaign strategies, fundraising structures, and debates over money’s role in democratic governance—both federally and at the state level.

For readers tracking election law, campaign finance reform, or state-level ripple effects, McCutcheon remains a cornerstone case in understanding how constitutional doctrine translates into political reality.