UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

_______________________________________ 

 ) 

REPUBLICAN NATIONAL COMMITTEE, ) 

et al., ) 

 Plaintiffs, ) Civ. No. 14-853 (CRC) 

 ) 

 v. ) 

 ) 

FEDERAL ELECTION COMMISSION, ) ANSWER 

 ) 

 Defendant. ) 

_______________________________________) 

DEFENDANT FEDERAL ELECTION COMMISSION’S 

ANSWER TO PLAINTIFFS’ COMPLAINT 

Defendant Federal Election Commission (“FEC” or “Commission”) submits this answer 

to plaintiffs’ Verified Complaint for Declaratory and Injunctive Relief (Docket No. 1). Any 

allegation not specifically responded to below, including allegations that appear in headings, is 

DENIED. The Commission responds as follows: 

1. This paragraph contains plaintiffs’ characterizations of legal claims in their own 

Complaint, to which no response is required. 

2. This paragraph contains plaintiffs’ characterizations of legal claims in their own 

Complaint and conclusions of law, to which no response is required. To the extent a response is 

required: Admit that the provisions of law challenged by plaintiffs prohibit activities that they 

indicate they wish to do, but deny that there is “no cognizable anti-corruption interest” for those 

provisions. 

3. This paragraph contains plaintiffs’ characterizations of legal claims in their own 

Complaint, conclusions of law, and a judicial decision, to which no response is required. To the 

extent a response is required: Admit that this paragraph accurately quotes the majority opinion 

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in Citizens United v. FEC, 558 U.S. 310, 357 (2010), with the words “including those made by 

corporations” omitted and replaced by ellipses. 

4. This paragraph contains plaintiffs’ characterizations of legal claims in their own 

Complaint, conclusions of law, and judicial decisions, to which no response is required. To the 

extent a response is required: Admit that this first sentence of this paragraph appears to 

characterize the holding in Colorado Republican Federal Campaign Committee v. FEC, 518 

U.S. 604 (1996) (“Colorado I”), which speaks for itself. Admit that the sentence following the 

first Colorado I citation accurately quotes the plurality opinion in that case, with an alteration to 

capitalization in brackets, and the words “present equally in both instances” omitted and replaced 

by ellipses. Admit that the plurality opinion in Colorado I states the holding, pursuant to Marks 

v. United States, 430 U.S. 188, 193 (1977), which speaks for itself. Admit that the last sentence 

of the paragraph accurately quotes the plurality opinion in Colorado I. 

5. This paragraph contains plaintiffs’ characterizations of legal claims in their own 

Complaint, conclusions of law, an FEC press release, and statutes and regulations, to which no 

response is required. To the extent a response is required: Admit that the first sentence of this 

paragraph appears to characterize a portion of the FEC Statement on Carey v. FEC: Reporting 

Guidance for Political Committees that Maintain a Non-Contribution Account, which speaks for 

itself. Admit that the language of the press release refers only to “nonconnected political 

committees.” Admit that 2 U.S.C. § 441i(b) generally prohibits state and local party committees 

from engaging in any federal election activity using funds that are raised outside of the limits in 

2 U.S.C. § 441a(a)(1)(D), with a limited exception for certain federal election activity, 2 U.S.C. 

§ 441i(b)(2). Admit that the third sentence of this paragraph accurately quotes 11 C.F.R. 

§ 300.2(g). Admit that the fourth sentence of this paragraph accurately quotes 11 C.F.R. 

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§ 300.2(k). Admit that 11 C.F.R. § 300.2(k) defines certain funds as “non-Federal funds,” and 

that such funds may be regulated by the states, including Louisiana. 

6. Deny that this Court has jurisdiction under the Bipartisan Campaign Reform Act 

of 2002 (“BCRA”), Pub. L. No. 107-155, § 403(a)(1), 116 Stat. 81, 113-14, because plaintiffs’ 

claims are neither substantial nor justiciable under that special review provision. Deny that 

BCRA §§ 403(a)(4) and (d)(2) are applicable. Admit that the paragraph accurately quotes from 

the statute, with an alteration to capitalization in brackets, except that plaintiffs have substituted 

the word “this” for the word “the” in the fourth-to-last word in the quotation. 

7. Deny that this Court has jurisdiction under BCRA § 403 because plaintiffs’ claims 

are neither substantial nor justiciable under that special review provision. Admit that the 

paragraph accurately quotes BCRA § 403, with certain provisions omitted and replaced by 

ellipses. 

8. Admit that this Court has jurisdiction over the claims of the Republican Party of 

Louisiana (“LAGOP”), Jefferson Parish Republican Parish Executive Committee (“JPGOP”), 

and Orleans Parish Republican Executive Committee (“OPGOP”) pursuant to 28 U.S.C. § 1331 

and 28 U.S.C. §§ 2201-02. Pursuant to Wagner v. FEC, 717 F.3d 1007 (D.C. Cir. 2013),

jurisdiction over the claims of plaintiff Republican National Committee (“RNC”) and the two 

individual plaintiffs exists only to the extent provided in 2 U.S.C. § 437h. 

9. Deny that this Court has jurisdiction under BCRA § 403 because plaintiffs’ claims 

are neither substantial nor justiciable under that special review provision. Admit that the 

paragraph accurately quotes BCRA § 403, with the word “is” omitted and replaced with ellipses, 

the words “this Act” omitted twice and replaced with “[BCRA],” and the word “elects” altered as 

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“elect[].” Admit that BCRA § 403 does, in applicable cases, provide for a three-judge court and 

direct appeal to the United States Supreme Court. 

10. Admit that venue is proper under 28 U.S.C. § 1391(e)(1). Deny that this Court 

has jurisdiction under BCRA § 403 because plaintiffs’ claims are neither substantial nor 

justiciable under that special review provision. 

11. Admit the first, second, and third sentences of this paragraph. The Commission 

is without knowledge or information sufficient to admit or deny the fourth and fifth sentences of 

this paragraph. 

12. Admit the first two sentences of the paragraph. The Commission is without 

knowledge or information sufficient to admit or deny the third and fourth sentences of this 

paragraph. 

13. Admit the first and second sentences of this paragraph. The Commission is 

without knowledge or information sufficient to admit or deny the remainder of this paragraph. 

14. Admit the first two sentences of this paragraph. The Commission is without 

knowledge or information sufficient to admit or deny the remainder of this paragraph. 

15. Admit the first sentence of this paragraph. The Commission is without 

knowledge or information sufficient to admit or deny the second and third sentences of this 

paragraph. 

16. Admit the first sentence of this paragraph. The Commission is without 

knowledge or information sufficient to admit or deny the second and third sentences of this 

paragraph. 

17. Admit that the Commission is the independent agency of the United States 

government with statutory authority over the administration, interpretation, and civil 

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enforcement of the Federal Election Campaign Act, 2 U.S.C. §§ 431-57 (“FECA”), including 

BCRA. See 2 U.S.C. §§ 437c(b)(1), 437d(a)(7)-(8), 437g, 438(a)(8). 

18. This paragraph and its footnote contain plaintiffs’ characterizations of a judicial 

decision, to which no response is required. To the extent a response is required: Admit that this 

paragraph appears to characterize the holding in SpeechNow.org v. FEC, 599 F.3d 686 (D.C. Cir. 

2010) (en banc), which speaks for itself. Admit that the block quote accurately quotes language 

from the opinion in SpeechNow, with an alteration to capitalization in brackets. 

19. This paragraph contains plaintiffs’ characterizations of an FEC Advisory Opinion, 

to which no response is required. To the extent a response is required: Admit that this paragraph 

appears to characterize the Commission’s Advisory Opinion 2010-09 (Club for Growth), which 

speaks for itself. Admit that the block quote accurately quotes the language of the attachment to 

the Commission’s opinion, except that “SpeechNow v. FEC” was italicized in the original. 

20. This paragraph contains plaintiffs’ characterizations of an FEC Advisory Opinion, 

to which no response is required. To the extent a response is required: Admit that this paragraph 

appears to characterize the Commission’s Advisory Opinion 2010-11 (Commonsense Ten), 

which speaks for itself. 

21. This paragraph contains plaintiffs’ characterizations of a judicial decision, 

conclusions of law, and a stipulated order and consent judgment, to which no response is 

required. To the extent a response is required: Admit that the first sentence of this paragraph 

appears to characterize the holding in Carey v. FEC, 791 F. Supp. 2d 121 (D.D.C. 2011), which 

speaks for itself. Admit that the second sentence of this paragraph appears to characterize the 

stipulated order and consent judgment entered in that case, which speaks for itself. 

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22. This paragraph and its footnote contains plaintiffs’ characterizations of provisions 

of FECA, a judicial decision, and an FEC press release, to which no response is required. To the 

extent a response is required: Admit that this paragraph appears to characterize a portion of the 

FEC Statement on Carey v. FEC: Reporting Guidance for Political Committees that Maintain a 

Non-Contribution Account, which speaks for itself. Admit that the block quote accurately quotes 

from that press release, with emphasis and a footnote reference added. Admit that the footnote 

appears to characterize 2 U.S.C. §§ 441a(a)(1), 441a(a)(3), and McCutcheon v. FEC, 134 S. Ct. 

1434 (2014), which speak for themselves. 

23. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph generally appears to characterize a portion of the opinion in 

McConnell v. FEC, 540 U.S. 93 (2003), which speaks for itself. Deny that the opinion discusses 

separate accounts for making independent expenditures and contributions to candidates. 

24. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

25. This paragraph contains conclusions of law and plaintiffs’ characterizations of an 

FEC press release and campaign guide, to which no response is required. To the extent a 

response is required: Admit that the portion of the first sentence before the colon appears to 

characterize portions of both the FEC Statement on Carey v. FEC: Reporting Guidance for 

Political Committees that Maintain a Non-Contribution Account and the Federal Election 

Commission Campaign Guide for Nonconnected Committees, which speak for themselves. 

Admit that the paragraph accurately quotes from the cited Campaign Guide. Admit that the last 

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sentence appears to draw legal conclusions from these two documents, which speak for 

themselves. 

26. Admit that RNC and LAGOP regularly receive contributions from individuals and 

will continue to do so. Admit that RNC regularly makes independent expenditures. The 

Commission is without knowledge or information sufficient to admit or deny whether RNC will 

continue to do so and whether it regularly makes or will make “other independent 

communications that refer to a federal candidate.” Deny that LAGOP regularly makes 

independent expenditures. The Commission is without knowledge or information sufficient to 

admit or deny whether LAGOP will do so in the future and whether it regularly makes or will 

make “other independent communications that refer to a federal candidate.” The third and fourth 

sentences of this paragraph are conclusions of law to which no response is required. To the 

extent responses are required: Admit that 2 U.S.C. § 441a(a)(1)(B) limits the amount that 

persons may contribute annually to national political party committees, the current limit is 

$32,400, and independent expenditures must be paid for using those funds. Price Index 

Adjustments for Contribution and Expenditure Limitations and Lobbyist Bundling Disclosure 

Threshold, 78 Fed. Reg. 8530-32 (Feb. 6, 2013). Admit that 2 U.S.C. § 441a(a)(1)(D) limits the 

amount that persons may contribute annually to federal political committees established by state 

and local political party committees, the limit is $10,000, the limit is shared in certain 

circumstances, and independent expenditures must be paid for using those funds. The 

Commission is without knowledge or information sufficient to admit or deny whether LAGOP’s 

limit is shared with district and local parties in Louisiana. The Commission is without 

knowledge or information sufficient to admit or deny the last sentence of this paragraph. 

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27. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

28. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

29. The Commission is without knowledge or information sufficient to admit or deny 

the first sentence of this paragraph. The second sentence contains conclusions of law, to which 

no response is required. To the extent a response is required: Admit that 2 U.S.C. § 441i(b) 

generally prohibits LAGOP, JPGOP, and OPGOP from using funds for federal election activity 

that are raised outside of the limit of 2 U.S.C. § 441a(a)(1)(D), with a limited exception for 

certain federal election activity, 2 U.S.C. § 441i(b)(2). The Commission is without knowledge 

or information sufficient to admit or deny the remainder of the second sentence. 

30. The Commission is without knowledge or information sufficient to admit or deny 

the first two sentences of this paragraph, except that the Commission admits that U.S. Senator 

Mary Landrieu is running for re-election in November 2014. The third, fourth, and fifth 

sentences contain conclusions of law, to which no response is required. To the extent a response 

is required: Admit that 2 U.S.C. § 441i(b) prohibits LAGOP from engaging in federal election 

activity similar to the described communication using funds that are raised outside of the limit of 

2 U.S.C. § 441a(a)(1)(D). Admit that the block quote accurately quotes 2 U.S.C. 

§ 431(20)(A)(iii), although it cites 2 U.S.C. § 431(20)(A)(iv). Admit that 2 U.S.C. 

§ 441a(a)(1)(D) limits to $10,000 the amount that persons may contribute annually to federal 

political committees established by the state and local political committees of each party in each 

state. The Commission is without knowledge or information sufficient to admit or deny whether 

LAGOP, JPGOP, and OPGOP must share the base limit. 

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31. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

32. The Commission is without knowledge or information sufficient to admit or deny 

the first sentence of this paragraph. Deny the second sentence of this paragraph. The third 

sentence contains conclusions of law, including speculation about this Court’s jurisdiction over 

this case for several years into the future, to which no response is required. To the extent a 

response is required: Admit that this sentence appears to characterize a portion of the holding in

FEC v. Wisconsin Right to Life, Inc., 551 U.S. 449, 461-63 (2007), which speaks for itself. 

33. Admit that plaintiffs will face a credible threat of civil enforcement proceedings if 

they proceed with activities in violation of FECA. Deny that plaintiffs will face a credible threat 

of criminal prosecution absent the required knowing and willful intent. 

34. The Commission is without knowledge or information sufficient to admit or deny 

the first sentence of this paragraph. Deny the second and third sentences of this paragraph. 

35. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-34 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

36. Admit that RNC and LAGOP are federal political party committees. The 

Commission is without knowledge or information sufficient to admit or deny whether they want 

to form non-contribution accounts. The part of the sentence following the comma appears to 

contain plaintiffs’ characterizations of an FEC press release, to which no response is required. 

To the extent a response is required: Admit that this portion of the paragraph appears to 

characterize a portion of the FEC Statement on Carey v. FEC: Reporting Guidance for Political 

Committees that Maintain a Non-Contribution Account, which speaks for itself. 

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37. This paragraph contains plaintiffs’ characterizations of an FEC press release, to 

which no response is required. To the extent a response is required: Admit that this paragraph 

appears to characterize a portion of the FEC Statement on Carey v. FEC: Reporting Guidance 

for Political Committees that Maintain a Non-Contribution Account, which speaks for itself. 

38. This paragraph contains conclusion of law, to which no response is required. To 

the extent a response is required: Admit that 2 U.S.C. § 441i(a) prohibits RNC from spending 

funds raised outside the limits of 2 U.S.C. § 441a(a)(1)(B). Admit that 2 U.S.C. § 441i(b) 

generally prohibits LAGOP, JPGOP, and OPGOP from spending funds raised outside the limits 

of 2 U.S.C. § 441a(a)(1)(D) for federal election activity, with a limited exception for certain 

federal election activity, 2 U.S.C. § 441i(b)(2). 

39. This paragraph contains plaintiffs’ characterizations of legal claims in their own 

Complaint, to which no response is required. Deny that 2 U.S.C. § 441i is unconstitutional. 

40. Deny the first sentence of this paragraph. The second sentence contains 

plaintiffs’ characterizations of judicial decisions and conclusions of law, to which no response is 

required. To the extent a response is required: Admit that the second sentence appears to 

characterize portions of the opinion in McConnell v. FEC, 540 U.S. 93 (2003), one of the 

opinions in McConnell v. FEC, 251 F. Supp. 2d 176 (D.D.C. 2003), and the dissent in 

McCutcheon v. FEC, 134 S. Ct. 1434 (2014), which speak for themselves. Admit that the second 

sentence accurately quotes one of the district court opinions in McConnell, with “ha[d]” 

substituted for “have,” and that the quote also appears in an altered form in the McCutcheon 

dissent. The third sentence contains plaintiffs’ characterizations of judicial decisions and 

conclusions of law, to which no response is required. To the extent a response is required: Deny 

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that this sentence accurately characterizes the holdings in Citizens United v. FEC, 558 U.S. 310 

(2010), and McCutcheon, 134 S. Ct. 1434. Deny the last sentence of the paragraph. 

41. This paragraph contains conclusion of law, to which no response is required. To 

the extent a response is required: Admit that 2 U.S.C. § 441i(a) prohibits RNC from spending 

funds raised outside the limits of 2 U.S.C. § 441a(a)(1)(B). Admit that 2 U.S.C. § 441i(b) 

prohibits LAGOP, JPGOP, and OPGOP from spending funds raised outside the limits of 2 

U.S.C. § 441a(a)(1)(D) for federal election activity, with a limited exception for certain federal 

election activity, 2 U.S.C. § 441i(b)(2). 

42. The first sentence of this paragraph contains conclusion of law, to which no 

response is required. To the extent a response is required: Admit that the first sentence appears 

to characterize the holdings in SpeechNow.org, 599 F.3d 686 (D.C. Cir. 2010), and Carey, 791 F. 

Supp. 2d 121 (D.D.C. 2011), which speak for themselves. Deny the second sentence of this 

paragraph. The third sentence of this paragraph contains plaintiffs’ characterizations of legal 

claims in their own Complaint, to which no response is required. Deny that 2 U.S.C. §§ 

441a(a)(1)(B) or (D) are unconstitutional. The first two paragraphs of the footnote 

accompanying this paragraph contain legal conclusions and plaintiffs’ characterizations of 

statutory provisions, a judicial decision, and claims in plaintiffs’ own Complaint, to which no 

response is required. Plaintiffs’ quotations from the statutory provisions and the judicial decision 

in these first two paragraphs are accurate, with the alterations indicated. The first sentence of the 

third paragraph of the footnote contains conclusion of law, to which no response is required. The 

Commission is without knowledge or information sufficient to admit or deny the last sentence of 

the footnote. 

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43. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-42 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

44. The first sentence of this paragraph contains conclusion of law, to which no 

response is required. To the extent a response is required: Admit that 2 U.S.C. § 441i(a) 

prohibits national party committees and their officers and agents from soliciting, receiving, or 

directing funds raised outside the limits of 2 U.S.C. § 441a(a)(1)(B). The Commission is without 

knowledge or information sufficient to admit or deny the remainder of this paragraph. 

45. The first sentence of this paragraph contains plaintiffs’ characterizations of an 

FEC Advisory Opinion, to which no response is required. To the extent a response is required: 

Admit that the first sentence of this paragraph appears to characterize the Commission’s 

Advisory Opinion 2011-12 (Majority PAC and House Majority PAC), which speaks for itself. 

The second sentence of this paragraph contains conclusion of law and characterizations of legal 

claims in plaintiffs’ own Complaint, to which no response is required. To the extent a response 

is required: Admit that 2 U.S.C. § 441i(a) prohibits officers and agents of national political 

parties from soliciting funds beyond the limit on contributions by persons to such parties 

contained in 2 U.S.C. § 441a(a)(1)(B). Deny that this base limit is unconstitutional. 

46. Deny. 

47. Deny the first sentence of this paragraph. The second sentence contains 

plaintiffs’ characterizations of judicial decisions and conclusions of law, to which no response is 

required. To the extent a response is required: Admit that the second sentence appears to 

characterize portions of the opinion in McConnell v. FEC, 540 U.S. 93 (2003), one of the 

opinions in McConnell v. FEC, 251 F. Supp. 2d 176 (D.D.C. 2003), and the dissent in 

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McCutcheon v. FEC, 134 S. Ct. 1434 (2014), which speak for themselves. Admit that the second 

sentence accurately quotes one of the district court opinions in McConnell, with “ha[d]” 

substituted for “have,” and that the quote also appears in an altered form in the McCutcheon 

dissent. The third sentence contains plaintiffs’ characterizations of judicial decisions and 

conclusions of law, to which no response is required. To the extent a response is required: Deny 

that this sentence accurately characterizes the holdings in Citizens United v. FEC, 558 U.S. 310 

(2010), and McCutcheon, 134 S. Ct. 1434. Deny the last sentence of the paragraph. 

48. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-47 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

49. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

50. This paragraph contains conclusions of law, to which no response is required. To 

the extent a response is required: Admit that 2 U.S.C. § 441i(b) generally prohibits state and 

local party committees from engaging in any federal election activity using funds that are raised 

outside of the limit of 2 U.S.C. § 441a(a)(1)(D), with a limited exception for certain federal 

election activity, 2 U.S.C. § 441i(b)(2), and that the paragraph accurately quotes portions of 2 

U.S.C. § 441a(a)(1)(D). 

51. This paragraph contains conclusions of law, to which no response is required. To 

the extent a response is required: Admit that the paragraph accurately quotes 2 U.S.C. 

§ 431(20)(A), which speaks for itself. 

52. Deny. 

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53. This paragraph contains conclusions of law and plaintiffs’ characterizations of 

legal claims in their own Complaint, to which no response is required. To the extent a response 

is required: Admit that 2 U.S.C. § 441i(c) prohibits funds raised outside the Act’s limitations, 

prohibitions and reporting requirements from being spent on fundraising for federal election 

activity. Deny that 2 U.S.C. § 441i(c) is unconstitutional. 

54. Deny the first sentence of this paragraph. The second sentence contains 

plaintiffs’ characterizations of judicial decisions and conclusions of law, to which no response is 

required. To the extent a response is required: Admit that the second sentence appears to 

characterize portions of the opinion in McConnell v. FEC, 540 U.S. 93 (2003), one of the 

opinions in McConnell v. FEC, 251 F. Supp. 2d 176 (D.D.C. 2003), and the dissent in 

McCutcheon v. FEC, 134 S. Ct. 1434 (2014), which speak for themselves. Admit that the second 

sentence accurately quotes one of the district court opinions in McConnell, with “ha[d]” 

substituted for “have,” and that the quote also appears in an altered form in the McCutcheon 

dissent. The third sentence contains plaintiffs’ characterizations of judicial decisions and 

conclusions of law, to which no response is required. To the extent a response is required: Deny 

that this sentence accurately characterizes the holdings in Citizens United v. FEC, 558 U.S. 310 

(2010), and McCutcheon, 134 S. Ct. 1434. Deny the last sentence of the paragraph. 

THE COMPLAINT’S PRAYER FOR RELIEF

1-12. Plaintiffs are not entitled to the relief requested or to any other relief. 

DEFENDANT FEDERAL ELECTION COMMISSION’S 

AFFIRMATIVE DEFENSE 

1. The Complaint fails to state a claim upon which relief can be granted. 

 

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 Respectfully submitted, 

Lisa J. Stevenson (D.C. Bar No. 457628) 

Deputy General Counsel — Law 

lstevenson@fec.gov 

 

Kevin Deeley 

Acting Associate General Counsel 

kdeeley@fec.gov 

Harry J. Summers 

Assistant General Counsel 

hsummers@fec.gov 

/s/ Seth Nesin 

Seth Nesin 

Greg J. Mueller (D.C. Bar No. 462840) 

Charles Kitcher (D.C. Bar No. 986226) 

 Attorneys 

 snesin@fec.gov 

gmueller@fec.gov 

 ckitcher@fec.gov 

 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street NW 

 Washington, DC 20463 

August 4, 2014 (202) 694-1650 

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