The Colorado Republican case recognized the right of political party committees to make independent expenditures. In so holding, the Court rejected the Commission's prior use of a conclusive or irrebuttable presumption that all party expenditures are by definition coordinated with the party's candidates. But that is all the Court held. It plainly is true that independent expenditures by parties must be truly independent, and that in setting the rules for establishing such independence, the Commission can and should take into account the unique position that parties occupy in relation to their candidates. Parties are not like other political committees or other independent spenders.
Parties are, by their very nature, inextricably linked to their candidates.
They nominate and sponsor their candidates. They raise money in conjunction with their candidates. Typically, they conduct campaigns as a joint venture with their candidates. It is little surprise, then, that a majority of the Supreme Court concluded in Colorado Republican that parties typically do operate in coordination with their candidates. Thus, Colorado Republican is an unusual case.