8 provided to their contributions to candidates or parties. The Court has explained that contributions to a candidate or party pose a greater risk of quid pro quo corruption than do expenditures. See Buckley, 424 U.S. at 46-47. At the same time, the Court has stated that limits on contributions to candidates or parties pose only a “marginal restriction upon the contributor’s ability to engage in free communication.” Id. at 20-21. By contrast, expenditure restrictions limit “political expression at the core of our electoral process and of the First Amendment freedoms.” Id. at 39 (internal quotation marks omitted). A “restriction on the amount of money a person or group can spend on political communication during a campaign necessarily reduces the quantity of expression by restricting the number of issues discussed, the depth of their exploration, and the size of the audience reached.” Id. at 19. The Court’s jurisprudence, in short, reflects a “fundamental constitutional difference between money spent to advertise one’s views independently of the candidate’s campaign and money contributed to the candidate to be spent on his campaign.” NCPAC, 470 U.S. at 497 (emphases added); see also Randall v. Sorrell, 548 U.S. 230, 241-42 (2006).4 4 Many have criticized the distinction between contributions and expenditures because, in their view, they are “two sides of the same First Amendment coin.” Buckley, 424 U.S. at 241 (opinion of Burger, C.J.). Some contend that limits on contributions and expenditures are both suspect under the First Amendment. See id.; id. at 290 (opinion of Blackmun, J); see also Shrink Mo. Gov’t PAC, 528 U.S. at 410 (Thomas, J., dissenting). Others argue that the interest in limiting contributions similarly justifies restricting expenditures. See Buckley, 424 U.S. at 260-62 (opinion of White, J.). The Court thus far has rebuffed both critiques and adhered to the Buckley divide. See Randall, 548 U.S. at 242 (“Over the last 30 years, in considering the constitutionality of a host of different

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