	Introduction

The First Amendment to the U.S. Constitution provides that "Congress shall make no law ... abridging the freedom of speech, or of the press." This provision limits the government's power to restrict speech. In 1976, the Supreme Court issued its landmark campaign finance ruling in Buckley v. Vale o. In Buckley , the Court found that limits on campaign contributions, which involve giving money to an entity, and expenditures, which involve spending money directly for electoral advocacy, implicate rights of political expression and association under the First Amendment. From these general principles, the Court concluded that contributions and expenditures facilitate an interchange of ideas, and cannot be regulated as mere conduct unrelated to their underlying act of communication. The Court in Buckley , however, afforded different degrees of First Amendment protection to contributions and expenditures. Contribution limits are subject to more lenient review, the Court found, because they impose only a marginal restriction on speech and will be upheld if the government can demonstrate that they are a "closely drawn" means of achieving a "sufficiently important" governmental interest. On the other hand, expenditure limits are subject to strict scrutiny because they impose a substantial restraint on speech. That is, limits on expenditures must be narrowly tailored to serve a compelling governmental interest. Therefore, in Buckley and its progeny, the Court has generally upheld limits on contributions, finding that they serve the governmental interest of protecting elections from corruption, while invalidating limits on independent expenditures, finding that they do not pose a risk of corruption. Importantly, the Court's recent case law has announced that only quid pro quo corruption or its appearance constitute a sufficiently important governmental interest to justify limits on contributions and expenditures. Although the Supreme Court's campaign finance jurisprudence has shifted over the years, the basic Buckley framework has generally been applied when determining whether a campaign finance limit violates the First Amendment. This report discusses current Supreme Court and other case law evaluating the constitutionality of limits on contributions and expenditures in various contexts. The Court has determined that limits on expenditures are subject to strict scrutiny review, and accordingly, has found them to be unconstitutional. Candidates Whose Opponents Self-Finance

The Supreme Court has ruled that a statute establishing a series of staggered increases in contribution limits for candidates whose opponents significantly self-finance their campaigns violates the First Amendment. Super PACs

The U.S. Court of Appeals for the District of Columbia has held that limits on contributions to groups that make only independent expenditures are unconstitutional. In McConnell v. FEC , the Court held that Section 213 of BCRA, which required political parties to choose between coordinated and independent expenditures after nominating a candidate, burdened the First Amendment right of parties to make unlimited independent expenditures. Corporations and Labor Unions

The Supreme Court has held that limits on corporate, and it appears labor union, expenditures that are made independently of any candidate or political party are unconstitutional under the First Amendment. Such expenditures are protected speech, regardless of whether the speaker is a corporation. As a result, in 2014, the Court overturned limits on aggregate contributions.
The First Amendment to the U.S. Constitution provides that "Congress shall make no law ... abridging the freedom of speech, or of the press." This provision limits the government's power to restrict speech. In 1976, the Supreme Court issued its landmark campaign finance ruling in Buckley v. Valeo. In Buckley, the Court determined that limits on campaign contributions, which involve giving money to an entity, and expenditures, which involve spending money directly for electoral advocacy, implicate rights of political expression and association under the First Amendment. In view of the fact that contributions and expenditures facilitate speech, the Court concluded, they cannot be regulated as mere conduct.
The Court in Buckley, however, afforded different degrees of First Amendment protection to contributions and expenditures. Contribution limits are subject to more lenient review because they impose only a marginal restriction on speech, and will be upheld if the government can demonstrate that they are a "closely drawn" means of achieving a "sufficiently important" governmental interest. On the other hand, expenditure limits are subject to strict scrutiny because they impose a substantial restraint on speech. That is, limits on expenditures must be narrowly tailored to serve a compelling governmental interest. Therefore, in Buckley and its progeny, the Court has generally upheld limits on contributions, finding that they serve the governmental interest of protecting elections from corruption, while invalidating limits on independent expenditures, finding that they do not pose a risk of corruption. Importantly, the Court's recent case law has announced that only quid pro quo corruption or its appearance constitute a sufficiently important governmental interest to justify limits on contributions and expenditures. Although the Supreme Court's campaign finance jurisprudence has shifted over the years, the basic Buckley framework has generally been applied when determining whether a campaign finance limit violates the First Amendment.
This report discusses current Supreme Court and other case law evaluating the constitutionality of limits on contributions and expenditures. For example, while the Court has generally upheld reasonable limits on contributions, it has invalidated them when it found that they were too low, prohibited minors age 17 or under from contributing, and after determining that aggregate contribution limits serve as a complete ban once the aggregate amount has been reached. The Court has also ruled that a series of staggered increases in contribution limits for candidates whose opponents significantly self-finance their campaigns are unconstitutional. An appellate court has held that limits on contributions to groups making only independent expenditures are unconstitutional, which resulted in the creation of super PACs. Cases including McConnell, Davis, SpeechNow.org, McCutcheon, and Williams-Yulee are examined.
The Supreme Court has overturned limits on candidate expenditures, including limits on candidates using personal wealth to finance campaigns, as well as on independent expenditures by political parties. Further, the Court has held that requiring parties to choose between coordinated and independent expenditures after nominating a candidate is unconstitutional because it burdens the right of parties to make unlimited independent expenditures. On the other hand, the Court has upheld limits on party coordinated expenditures because they are functionally similar to contributions. The Court has also invalidated a long-standing prohibition on corporations, and it appears labor unions, using treasury funds for independent expenditures, finding that regardless of the speaker being a corporation, such expenditures are protected speech. Cases including Colorado Republican Federal Campaign Committee, Randall, Wisconsin Right to Life, and Citizens United are discussed.