Cite as: 572 U. S. ____ (2014)
11
Opinion of ROBERTS, C. J.
base limit. Id., at 38. The Court determined that circumvention could occur when an individual legally contributes
“massive amounts of money to a particular candidate
through the use of unearmarked contributions” to entities
that are themselves likely to contribute to the candidate.
Ibid. For that reason, the Court upheld the $25,000 aggregate limit.
Although Buckley provides some guidance, we think
that its ultimate conclusion about the constitutionality of
the aggregate limit in place under FECA does not control
here. Buckley spent a total of three sentences analyzing
that limit; in fact, the opinion pointed out that the constitutionality of the aggregate limit “ha[d] not been separately
addressed at length by the parties.” Ibid. We are now
asked to address appellants’ direct challenge to the aggregate limits in place under BCRA. BCRA is a different
statutory regime, and the aggregate limits it imposes
operate against a distinct legal backdrop.
Most notably, statutory safeguards against circumvention have been considerably strengthened since Buckley
was decided, through both statutory additions and the
introduction of a comprehensive regulatory scheme. With
more targeted anticircumvention measures in place today,
the indiscriminate aggregate limits under BCRA appear
particularly heavy-handed.
The 1976 FECA Amendments, for example, added another layer of base contribution limits. The 1974 version
of FECA had already capped contributions from political
committees to candidates, but the 1976 version added
limits on contributions to political committees. This
change was enacted at least “in part to prevent circumvention of the very limitations on contributions that this
Court upheld in Buckley.” California Medical Assn. v.
Federal Election Comm’n, 453 U. S. 182, 197–198 (1981)
(plurality opinion); see also id., at 203 (Blackmun, J.,
concurring in part and concurring in judgment). Because