States may cap political donors’ campaign contributions only if they can show that those limits are preventing corruption or the appearance of corruption, a federal appeals court ruled Tuesday. The ruling by a three-judge panel from the 9th U.S. Circuit Court of Appeals in a Montana case could make it more difficult for states to defend their restrictions on the amount of money that individual donors give candidates in state elections. States can limit contributions if they have a legitimate interest in doing so. But proving that state interest has changed since the U.S. Supreme Court’s 2010 ruling in the Citizens United case that said corporations can spend unlimited amounts in elections, a three-judge panel for the 9th U.S. Circuit Court of Appeals said.
Before the Citizens United decision, states only had to show they aimed to curb the influence of big money on politicians. After Citizens United, states must show more specifically that their laws are stopping an exchange of money for political favors, the opinion written by Judge Carlos Bea said.
“Now, the prevention of quid pro quo corruption, or its appearance, is the only sufficiently important state interest to justify limits on campaign contribution,” Bea wrote.
The ruling, which applies to the nine Western states in the 9th Circuit’s district, was made in a case that challenged Montana’s contribution limits as violating donors’ rights to free speech and association.