2
THOMPSON v. HEBDON
Per Curiam
eral Election Comm’n, 572 U. S. 185, 206–207 (2014); Citizens United v. Federal Election Comm’n, 558 U. S. 310,
359–360 (2010)). The court below explained that under its
precedent in this area “the quantum of evidence necessary
to justify a legitimate state interest is low: the perceived
threat must be merely more than ‘mere conjecture’ and ‘not
. . . illusory.’ ” 909 F. 3d, at 1034 (quoting Eddleman, 343
F. 3d, at 1092; some internal quotation marks omitted).
The court acknowledged that “McCutcheon and Citizens
United created some doubt as to the continuing vitality of
[this] standard,” but noted that the Ninth Circuit had recently reaffirmed it. 909 F. 3d, at 1034, n. 2.
After surveying the State’s evidence, the court concluded
that the individual-to-candidate contribution limit “ ‘focuses
narrowly on the state’s interest,’ ‘leaves the contributor free
to affiliate with a candidate,’ and ‘allows the candidate to
amass sufficient resources to wage an effective campaign,’ ”
and thus survives First Amendment scrutiny. Id., at 1036
(quoting Eddleman, 343 F. 3d, at 1092; alterations omitted); see also 909 F. 3d, at 1036–1039. The court also found
the individual-to-group contribution limit valid as a tool for
preventing circumvention of the individual-to-candidate
limit. See id., at 1039–1040.
In reaching those conclusions, the Ninth Circuit declined
to apply our precedent in Randall v. Sorrell, 548 U. S. 230
(2006), the last time we considered a non-aggregate contribution limit. See 909 F. 3d, at 1037, n. 5. In Randall, we
invalidated a Vermont law that limited individual contributions on a per-election basis to: $400 to a candidate for Governor, Lieutenant Governor, or other statewide office; $300
to a candidate for state senator; and $200 to a candidate for
state representative. JUSTICE BREYER’s opinion for the plurality observed that “contribution limits that are too low
can . . . harm the electoral process by preventing challengers from mounting effective campaigns against incumbent
officeholders, thereby reducing democratic accountability.”