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Federal appeals court rejects challenge to campaign finance law

[JURIST] The US Court of Appeals for the District of Columbia Circuit on Tuesday rejected [opinion, PDF] a challenge to a campaign finance law that set limits on federal donations to primary and general elections.

The law placed a per-election donation cap: $2,600 for primary elections and $2,600 for general elections.

A Florida couple, Laura Holmes and Paul Jost, brought an action against the Federal Election Commission (FEC) [official website] in 2014, arguing that they should be able to donate $5,200 during the general election, rather than being forced to split the maximum donation between the primary and general elections. Further, they argued, if spending $5,200 over both elections does not raise undue prospect of corruption, then donating all of the money during the general election should similarly be permitted.

The court, sitting en banc, unanimously rejected these arguments, stating that Congress has sound reasoning in choosing to place per-election caps, rather than per-cycle caps. It explained:

Congress's choice of a per-election structure thus is not a "prophylaxis-upon-prophylaxis"—a second anti-corruption measure layered on top of the base limits. Instead, the per-election structure is an essential ingredient of the base limits themselves—the first layer of prophylaxis. ... [T]here is no warrant for attempting to ascertain whether the per-election timeframe of the $2,600 base limit itself combats corruption. Rather, it is enough if that base limit as a whole (of which its time period is an integral element) prevents the appearance or actuality of corruption in a manner satisfying the closely drawn standard.
Ultimately the court upheld the per-election structure for setting contribution ceilings. The couple did not broadly challenge the constitutionality of a contribution limit itself.

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