The First Amendment to the U.S. Constitution provides that "Congress shall make no law ... abridging the freedom of speech, or of the press." This provision limits the government's power to restrict speech. In 1976, the Supreme Court issued its landmark campaign finance ruling in Buckley v. Vale o. In Buckley , the Court found that limits on campaign contributions, which involve giving money to an entity, and expenditures, which involve spending money directly for electoral advocacy, implicate rights of political expression and association under the First Amendment. A number of principles contributed to the Court's analogy between money and speech. First, the Court found that candidates need to amass sufficient wealth to amplify and effectively disseminate their message to the electorate. Second, restricting political contributions and expenditures imposes a restriction on the amount of money that a candidate can spend on communications, thereby reducing the number and depth of issues discussed and the size of the audience reached. This is because almost all modes of communicating ideas in a mass society require the spending of money. The Court further observed that the primary purpose of the First Amendment is to increase the quantity of public expression of political ideas. From these general principles, the Court concluded that contributions and expenditures facilitate an interchange of ideas, and cannot be regulated as mere conduct unrelated to their underlying act of communication. The Court in Buckley , however, afforded different degrees of First Amendment protection to contributions and expenditures. Contribution limits are subject to more lenient review, the Court found, because they impose only a marginal restriction on speech and will be upheld if the government can demonstrate that they are a "closely drawn" means of achieving a "sufficiently important" governmental interest. On the other hand, expenditure limits are subject to strict scrutiny because they impose a substantial restraint on speech. That is, limits on expenditures must be narrowly tailored to serve a compelling governmental interest. Therefore, in Buckley and its progeny, the Court has generally upheld limits on contributions, finding that they serve the governmental interest of protecting elections from corruption, while invalidating limits on independent expenditures, finding that they do not pose a risk of corruption. Importantly, the Court's recent case law has announced that only quid pro quo corruption or its appearance constitute a sufficiently important governmental interest to justify limits on contributions and expenditures. Quid pro quo corruption involves an exchange of money or something of value for an official act. Although the Supreme Court's campaign finance jurisprudence has shifted over the years, the basic Buckley framework has generally been applied when determining whether a campaign finance limit violates the First Amendment. This report discusses current Supreme Court and other case law evaluating the constitutionality of limits on contributions and expenditures in various contexts. First, it examines contribution limits, covering base limits, aggregate limits, limits on candidates whose opponents self-finance, minors, and super PACs. As noted above, the Court has generally upheld limits on contributions, but the report examines exceptions to this general rule. It also examines a recent case that distinguishes between judicial and political elections in upholding a ban on the personal solicitation of contributions by judicial candidates. Then the report discusses expenditure limits, including limits on expenditures by candidates, political parties, and corporations and labor unions. The Court has determined that limits on expenditures are subject to strict scrutiny review, and accordingly, has found them to be unconstitutional. The Supreme Court has generally upheld the constitutionality of reasonable limits on how much money a donor may contribute to a candidate. These contribution limits are known as "base limits." In contrast, as discussed in the section below, "aggregate limits" restrict how much money a donor may contribute in total to all candidates, parties, and political committees. In Buckley v. Valeo , the Court upheld the constitutionality of a Federal Election Campaign Act (FECA) limit on individuals making contributions to candidates. While finding that limits on both contributions and expenditures implicate rights of political expression and association under the First Amendment, the Court distinguished between the two. Unlike expenditure limits, which reduce the amount of expression, contribution limits involve "little direct restraint" on the speech of a contributor. The Court acknowledged that a contribution limit restricts an aspect of a contributor's freedom of association, that is, his or her ability to support a candidate. Nonetheless, the Court found that they still permit symbolic expression of support, and do not infringe on a contributor's freedom to speak about candidates and issues. Reasonable contribution limits, the Court noted, still permit people to engage in independent political expression, associate by volunteering on campaigns, and assist candidates by making limited contributions. Therefore, the Court found, limits on contributions are permissible so long as they are "closely drawn" to serve a "sufficiently important interest." In Buckley , the Court found that the government had demonstrated that preventing corruption or its appearance was sufficiently important to justify the FECA contribution limits. The Court recognized that contribution limits serve as one of FECA's primary means to combat improper influence on candidates by contributors. Thus, the Court concluded that both the reality and appearance of corruption as a result of large campaign contributions was a sufficiently compelling interest to warrant infringements on First Amendment liberties "to the extent that large contributions are given to secure a quid pro quo from [a candidate.]" Regarding whether the contribution limit was closely drawn, the Court found that it was relevant to examine the amount of the limit. Limits that are too low could significantly impede a candidate or political committee from amassing the necessary resources for effective communication. The Court concluded, however, that the FECA contribution limit at issue in Buckley would not negatively impact campaign funding. Since Buckley , the Court has similarly upheld the constitutionality of other contribution limits. In Nixon v. Shrink Missouri Government PAC , the Court upheld a state law imposing contribution limits on candidates running for state office. The Court observed that while contribution limits must be closely drawn to a sufficiently important interest, the amount of the limitation "need not be 'fine tuned.'" Under Buckley , the Court noted, a key inquiry regarding whether a contribution limit is too low is whether there is evidence demonstrating that the limit prevents a candidate from amassing sufficient funds for effective advocacy. Applying that principle, the Supreme Court has determined that certain contribution limits are too low and invalidated them under the First Amendment. In Randall v. Sorell , in a plurality opinion, the Court invalidated a Vermont law that included a limit of $400 on individual, party, and political committee contributions to certain state candidates, per two-year election cycle. The law did not provide for inflation adjustment. While unable to reach consensus on a single opinion, six Justices agreed that the contribution limits violated First Amendment free speech guarantees. The plurality opinion written by Justice Breyer, joined by two other Justices, found that the contribution limits in this case were substantially lower than limits it had previously upheld as well as limits in effect in other states, and that they were not narrowly tailored. The opinion also concluded that the limits substantially restricted candidates, particularly challengers, from being able to raise the funds necessary to run a competitive campaign; impeded parties from getting their candidates elected; and deterred individual citizens from volunteering on campaigns (because the law counted certain volunteer expenses toward a volunteer's individual contribution limit). The Supreme Court has held that aggregate limits on contributions are unconstitutional under the First Amendment. Aggregate limits restrict how much money a donor may contribute in total to all candidates, parties, and political committees. Characterizing them as a ban on further contributions once the aggregate amount has been reached, the Court has determined that they violate the First Amendment by infringing on political expression and association rights, without furthering the governmental interest of preventing quid pro quo corruption or its appearance. In McCutcheon v. F ederal E lection C ommission , the Supreme Court invalidated Section 307(b) of the Bipartisan Campaign Reform Act of 2002 (BCRA), which amended FECA, imposing biennial limits on aggregate contributions. These limits were adjusted for inflation each election cycle. For example, during the 2011-2012 election cycle, the law prohibited individuals from making contributions to candidates totaling more than $46,200, and to parties and political action committees (PACs) (with the exception of "super PACs") totaling more than $70,800. The base limits on contributions established by the BCRA were not at issue in this case and remain in effect. As a threshold matter, the plurality opinion in McCutcheon determined that it was unnecessary to revisit the contribution/expenditure distinction established in Buckley v. Valeo , and the differing standards of review applicable to each. According to the opinion, regardless of whether strict scrutiny or the "closely drawn" standard applies, the analysis "turns on the fit" between the government's stated objective and the means to achieve it. Applying that analysis to the aggregate contribution limits, the opinion found a "substantial mismatch" between the two, and concluded that even under the more lenient standard of review, the limits could not be upheld. Importantly, the opinion announced that throughout the Court's campaign finance cases dating back 40 years, it has identified only one legitimate governmental interest for restricting campaign financing: the prevention of quid pro quo corruption or its appearance. Essentially, quid pro quo corruption captures the notion of "a direct exchange of an official act for money." While acknowledging that the Court's campaign finance jurisprudence has not always discussed the concept of corruption clearly and consistently, and that the line between quid pro quo corruption and general influence may sometimes seem vague, the opinion said that efforts to ameliorate "influence over or access to" elected officials or political parties do not constitute a permissible governmental interest. According to the opinion, the spending of large sums of money in connection with elections, but absent an effort to control how an officeholder exercises his or her official duties, does not give rise to quid pro quo corruption.