On April 2, the United States Supreme Court released its much-anticipated decision in McCutcheon v. FEC, 572 U.S. __ (2014). The case was closely watched because it presented the Court the opportunity to revisit the framework of First Amendment campaign finance jurisprudence.

The modern constitutional analysis for campaign finance law has its origin in Buckley v. Valeo, 424 U.S. 1 (1976). There, the Court determined that contributions to candidates could be subject to more regulation than could election-related expenditures. This is because the Court has found that preventing actual or apparent quid pro quo corruption is the only governmental interest strong enough to justify regulation of campaign speech. Though the parties and amici in McCutcheon challenged Buckley’s contribution/expenditure distinction, the Court declined to revisit it.