8
MCCUTCHEON v. FEDERAL ELECTION COMM’N
Opinion of ROBERTS, C. J.
Government may regulate protected speech only if such
regulation promotes a compelling interest and is the least
restrictive means to further the articulated interest. See
Sable Communications of Cal., Inc. v. FCC, 492 U. S. 115,
126 (1989).
By contrast, the Court concluded that contribution
limits impose a lesser restraint on political speech because
they “permit[ ] the symbolic expression of support evidenced by a contribution but do[ ] not in any way infringe
the contributor’s freedom to discuss candidates and issues.” Buckley, 424 U. S., at 21. As a result, the Court
focused on the effect of the contribution limits on the
freedom of political association and applied a lesser but
still “rigorous standard of review.” Id., at 29. Under that
standard, “[e]ven a ‘ “significant interference” with protected rights of political association’ may be sustained if
the State demonstrates a sufficiently important interest
and employs means closely drawn to avoid unnecessary
abridgement of associational freedoms.” Id., at 25 (quoting Cousins v. Wigoda, 419 U. S. 477, 488 (1975)).
The primary purpose of FECA was to limit quid pro quo
corruption and its appearance; that purpose satisfied the
requirement of a “sufficiently important” governmental
interest. 424 U. S., at 26–27. As for the “closely drawn”
component, Buckley concluded that the $1,000 base limit
“focuses precisely on the problem of large campaign contributions . . . while leaving persons free to engage in
independent political expression, to associate actively
through volunteering their services, and to assist to a
limited but nonetheless substantial extent in supporting
candidates and committees with financial resources.” Id.,
at 28. The Court therefore upheld the $1,000 base limit
under the “closely drawn” test. Id., at 29.
The Court next separately considered an overbreadth
challenge to the base limit. See id., at 29–30. The challengers argued that the base limit was fatally overbroad