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registration drives. Non-profits in this category make no
contributions to federal candidates or parties.
The Supreme Court’s case law establishes that those nonprofit entities, like individual citizens, are constitutionally
entitled to raise and spend unlimited money in support of
candidates for elected office – with the narrow exception that,
under Austin, the Government may restrict to some degree
how non-profits spend donations received from the general
treasuries of for-profit corporations or unions. See Cal. Med.
Ass’n v. FEC, 453 U.S. 182, 202-03 (1981) (opinion of
Blackmun, J.); see also FEC v. Mass. Citizens for Life, Inc.
(MCFL), 479 U.S. 238, 259-65 (1986); NCPAC, 470 U.S. at
501; Citizens Against Rent Control, 454 U.S. at 296-99;
Buckley, 424 U.S. at 47; N.C. Right to Life, Inc. v. Leake, 525
F.3d 274, 292-93 (4th Cir. 2008).
Those principles were initially articulated in Cal-Med.
There, Justice Blackmun determined that “contributions to
political committees can be limited only if those contributions
implicate the governmental interest in preventing actual or
potential corruption, and if the limitation is no broader than
necessary to achieve that interest.” Cal-Med, 453 U.S. at 203
(opinion of Blackmun, J.). Applying that standard, he found
that “contributions to a committee that makes only
independent expenditures pose no such threat” of “actual or
potential corruption.” Id. “By pooling their resources,
adherents of an association amplify their own voices; the
association is but the medium through which its individual
members seek to make more effective the expression of their
own views.” Id. (citation and internal quotation marks
omitted). Justice Blackmun thus concluded that Government