Coordinated Party Expenditures in Federal
Elections: An Overview
R. Sam Garrett
Specialist in American National Government
L. Paige Whitaker
Legislative Attorney
May 15, 2014
Congressional Research Service
7-5700
www.crs.gov
RS22644
Coordinated Party Expenditures in Federal Elections: An Overview
Summary
A provision of federal campaign finance law, codified at 2 U.S.C. §441a(d), allows political party
committees to make expenditures on behalf of their general election candidates for federal office
and specifies limits on such spending. These “coordinated party expenditures” are important not
only because they provide financial support to campaigns, but also because parties and campaigns
may explicitly discuss how the money is spent. Although they have long been the major source of
direct party financial support for campaigns, coordinated expenditures have recently been
overshadowed by independent expenditures.
In a 1996 ruling, Colorado Republican Federal Campaign Committee v. Federal Election
Commission (FEC) (Colorado I), the U.S. Supreme Court found that political parties have a
constitutional right to make unlimited independent expenditures. Federal campaign finance law
defines an independent expenditure to include spending for a communication that expressly
advocates the election or defeat of a clearly identified candidate, and is not made in cooperation
or consultation with a candidate or a political party. In a subsequent case, Colorado II, however,
the Court ruled that a political party’s coordinated expenditures—that is, expenditures made in
cooperation or consultation with a candidate—may be constitutionally limited in order to
minimize circumvention of contribution limits. According to the Court, in contrast to independent
expenditures, coordinated party expenditures have no “significant functional difference” from
direct party candidate contributions.
Congress has not recently considered legislation specifically aimed at reducing or eliminating
existing limits on coordinated party expenditures. Nonetheless, the concept remains a component
of the debate over the strength of modern political parties. In the 113th Congress, bills primarily
related to public financing of campaigns (H.R. 20; H.R. 268; H.R. 269; H.R. 270; S. 2023) would
also permit additional coordinated party expenditures. Revisiting coordinated party expenditure
limits might also be relevant following an April 2014 U.S. Supreme Court decision in
McCutcheon v. FEC.
Those who support existing limits on coordinated party expenditures argue that the caps reduce
potential corruption and the amount of money in politics. Opponents maintain that the limits are
antiquated, particularly because political parties may make unlimited independent expenditures
supporting their candidates. If the caps were lifted and fundraising patterns remained consistent
with those discussed here, it appears that neither party would have a substantial resource
advantage over the other. It is important to note, however, that individual circumstances would
determine particular fundraising and spending decisions.
This report will be updated occasionally as events warrant.
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Coordinated Party Expenditures in Federal Elections: An Overview
Contents
What Are Coordinated Party Expenditures? .................................................................................... 1
Overview of Relevant Supreme Court Precedent ............................................................................ 2
Independent Spending Limits Found Unconstitutional and Contribution Limits
Upheld: Buckley v. Valeo ........................................................................................................ 2
Independent Party Spending Limits Found Unconstitutional and Coordinated Party
Expenditure Limits Upheld: Colorado I and II ...................................................................... 2
Recent Legislative Activity .............................................................................................................. 4
Financial Overview and Analysis .............................................................................................. 5
Figures
Figure 1. National Party Coordinated and Independent Expenditures ............................................. 6
Figure 2. Total Receipts of Democratic and Republican Party Committees .................................... 7
Tables
Table 1. National Party Coordinated and Independent Expenditures .............................................. 5
Table 2. Total Receipts of Democratic and Republican Party Committees ..................................... 7
Contacts
Author Contact Information............................................................................................................. 9
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Coordinated Party Expenditures in Federal Elections: An Overview
What Are Coordinated Party Expenditures?
Federal campaign finance law provides political parties with three major options for providing
financial support to House, Senate, and presidential candidates: (1) direct contributions, (2)
coordinated expenditures, and (3) independent expenditures.1 With direct contributions, parties
give money (or in the case of in-kind contributions, financially valuable services) to individual
campaigns, but such contributions are subject to strict limits; most party committees are limited to
direct contributions of $5,000 per candidate, per election.2 Since the 1996 Colorado I Supreme
Court ruling (discussed below), parties may make independent expenditures, which are not
limited, on anything allowable by law, but may not coordinate those expenses with candidates.
Coordinated expenditures3 allow parties (notwithstanding other provisions in the law regulating
contributions to campaigns) to buy goods or services on behalf of a campaign, and to discuss
those expenditures with the campaign. Candidates may request that parties make coordinated
expenditures, and may request specific purchases, but parties may not give this money directly to
campaigns. Because parties are the spending agents, they (not candidates) report their coordinated
expenditures to the FEC.
Coordinated party expenditures are subject to limits based on office sought, state, and voting-age
population (VAP). Exact amounts are determined by formula and updated annually by the FEC.4
Limits for Senate candidates in 2014, adjusted for inflation, range from $94,500 in states with the
smallest VAPs to approximately $2.8 million in California.5 In 2014 parties can make up to
$47,200 in coordinated expenditures in support of each House candidate in multi-district states,
and $94,500 in support of House candidates in single-district states.6 State party committees may
authorize their national counterparts to make coordinated-party expenditures on their behalf (or
vice versa). If such agreements exist, one party could essentially assume the spending limit for
another in particular states, in which case the designated party could spend up to its own limit and
up to the other party’s limit. Parties may also make coordinated expenditures on behalf of
presidential candidates. Limits for the 2016 cycle have not been announced.
1 For a discussion of campaign finance policy generally, see CRS Report R41542, The State of Campaign Finance
Policy: Recent Developments and Issues for Congress, by R. Sam Garrett.
2 2 U.S.C. §441a(a).
3 Federal Election Commission (FEC) regulations define “coordinated” as “cooperation, consultation or concert with,
or at the request or suggestion of, a candidate, a candidate’s authorized committee, or a political party committee.” 11
CFR §109.20.
4 Senate limits are based primarily on VAP, whereas House limits are based primarily on a flat allocation. Specifically,
the limits for Senate candidates and House candidates in single-district states are the greater of 2 cents multiplied by the
VAP, adjusted for inflation, or $20,000, adjusted for inflation. The limit for House candidates in multi-district states is
$10,000 (the 1974 base amount) plus adjustments for inflation, which have greatly increased the current limits over
base amounts. See 2 U.S.C. §441a(d)(3).
5 For 2014 limits, see Federal Election Commission, “Price Index Adjustments for Expenditure Limitations and
Lobbyist Bundling Disclosure Threshold,” 79 Federal Register 7190-7192, February 6, 2014. If a joint expenditure
designation between state and national parties were in place, the spending party, relying on both parties’ limits, could
spend $189,000 and $5.6 million respectively.
6 2 U.S.C. §§441a(d)(3), 441a(c). If a joint expenditure designation between state and national parties were in place, the
spending party, relying on both parties’ limits, could spend $94,400 and $189,000 respectively.
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Coordinated Party Expenditures in Federal Elections: An Overview
Overview of Relevant Supreme Court Precedent7
Independent Spending Limits Found Unconstitutional and
Contribution Limits Upheld: Buckley v. Valeo
In its 1976 decision, Buckley v. Valeo,8 the Supreme Court considered the constitutionality of the
Federal Election Campaign Act (FECA),9 and determined that limits on independent expenditures
were unconstitutional, while it upheld reasonable limits on contributions.10 FECA defines an
“independent expenditure” to include spending for a communication that expressly advocates the
election or defeat of a clearly identified candidate, and is not made in concert or cooperation with
or at the request or suggestion of a candidate or a political party.11 In contrast, a “contribution” is
generally given to a candidate or party, and is defined to include any gift of money or anything of
value made by any person for the purpose of influencing a federal election.12
Most notably, the Buckley Court determined that the spending of money, whether in the form of
contributions or expenditures, is a form of “speech” protected by the First Amendment. However,
according to the Court, contributions and expenditures invoke different degrees of First
Amendment protection.13 Recognizing contribution limitations as one of FECA’s “primary
weapons against the reality or appearance of improper influence” on candidates by contributors,
the Court found that these limits “serve the basic governmental interest in safeguarding the
integrity of the electoral process.”14 On the other hand, the Court determined that FECA’s
expenditure limits on individuals, political action committees (PACs), and candidates impose
“direct and substantial restraints on the quantity of political speech” and are not justified by an
overriding governmental interest.15
Independent Party Spending Limits Found Unconstitutional and
Coordinated Party Expenditure Limits Upheld: Colorado I and II
In Colorado Republican Federal Campaign Committee v. Federal Election Commission (FEC)
(Colorado I (1996)),16 the Supreme Court found that political parties have a constitutional right to
make unlimited independent expenditures. The Court determined that FECA’s coordinated party
7 This portion of the report was written by L. Paige Whitaker, Legislative Attorney.
8 424 U.S. 1 (1976). For further discussion of Buckley and Colorado I and II, see CRS Report RL30669, The
Constitutionality of Campaign Finance Regulation: Buckley v. Valeo and Its Supreme Court Progeny, by L. Paige
Whitaker.
9 2 U.S.C. §431 et seq.
10 For further discussion, see CRS Legal Sidebar WSLG909, Campaign Finance Law: What is a “Coordinated
Communication” versus an “Independent Expenditure”?, by L. Paige Whitaker.
11 2 U.S.C. §431(17).
12 2 U.S.C. §431(8)(A)(i).
13 Buckley, 424 U.S. at 24.
14 Id. at 59.
15 Id. at 39.
16 518 U.S. 604 (1996).
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expenditure limit17 was unconstitutionally enforced against a party’s funding of radio
advertisements directed against a likely opponent.
Specifically, this case concerned the constitutionality of the coordinated party expenditure limit as
applied to expenditures for radio ads by the Colorado Republican Party (CRP) that criticized the
likely Democratic Party candidate in the 1986 U.S. Senate election.18 The Court’s ruling turned
on whether CRP’s ad purchase was an “independent expenditure,” a “campaign contribution,” or
a “coordinated expenditure.”19 The Court found that the CRP’s ad purchase was an independent
expenditure deserving constitutional protection. Independent expenditures, the Court held, do not
raise heightened governmental interests in regulation because the money is deployed to advance a
political point of view separate from a candidate’s viewpoint and, therefore, cannot be limited.20
The Court emphasized that the “constitutionally significant fact” of an independent expenditure is
the absence of coordination between the candidate and the source of the expenditure.21
The Court’s opinion in Colorado I was limited to the constitutionality of the application of
FECA’s coordinated party expenditure limit to an independent expenditure by the CRP. Later, in
FEC v. Colorado Republican Federal Campaign Committee (Colorado II),22 the Court considered
a facial challenge23 to the constitutionality of the limit on coordinated party spending. In
Colorado II, the Supreme Court ruled that a political party’s coordinated expenditures—unlike
genuine independent expenditures—may be constitutionally limited in order to minimize
circumvention of FECA contribution limits. As the Court explained, coordinated party
expenditures have no “significant functional difference” from direct party candidate
contributions.24
Relying on its holding in Colorado I, in a case evaluating the constitutionality of the Bipartisan
Campaign Reform Act of 2002 (BCRA),25 the Court invalidated a statutory provision that
essentially required political parties to choose between making coordinated or independent
expenditures after nominating a candidate.26 In McConnell v. FEC,27 the Court determined that
the statute burdened the right of parties to make unlimited independent expenditures and
therefore, was unconstitutional.28
17 2 U.S.C. §441a(d)(3).
18 See Colorado I, 518 U.S. at 612.
19 Id. at 614, 615, 618, 622-623.
20 See id. at 614-615 (citing FEC v. National Conservative Political Action Committee (NCPAC), 479 U.S. 238 (1985)).
21 Id. at 617 (citing Buckley, 424 U.S. at 45-46; NCPAC, 479 U.S. at 498).
22 533 U.S. 431 (2001).
23 Generally, when a statute is challenged “facially,” a plaintiff is arguing that under all circumstances, the statute
operates unconstitutionally. By contrast, an “as-applied” challenge involves a plaintiff arguing that a statute is
unconstitutional as applied to the facts of a particular case or to a party.
24 Colorado II, 533 U.S. at 464.
25 P.L. 107-155.
26 Codified at 2 U.S.C. §441a(d)(4).
27 540 U.S. 93, 213 (2003), overruled in part by Citizens United v. FEC, 558 U.S. 310, 365-66 (2010) (finding that the
portion of McConnell that upheld BCRA’s restriction on independent spending for “electioneering communications”
relied on an anti-distortion interest that the Court rejected as unconvincing and insufficient).
28 See id. at 217.
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In Citizens United v. FEC,29 the Court overruled a separate portion of McConnell and invalidated
BCRA’s restriction on corporate and union spending for electioneering communications, as well
as the long-standing ban on such spending for independent expenditures.30 As the U.S. Court of
Appeals for the Fifth Circuit has found,31 it does not appear that Citizens United affected the
Supreme Court’s holding in Colorado II. In contrast to the coordinated party expenditure limit
addressed in Colorado II, Citizens United evaluated the constitutionality of limits on
independent—not coordinated—spending. Reiterating its holding in Buckley, the Court in
Citizens United found that while large campaign contributions create a risk of quid pro quo
candidate corruption, large independent expenditures do not. Therefore, in Buckley, the Citizens
United Court observed, it determined that limiting independent expenditures fails to serve any
substantial government interest in stemming either the reality or the appearance of such
corruption.32
Recent Legislative Activity
Reconsidering coordinated party expenditure limits is a consistent part of the debate over the role
of political parties compared with other political committees and “outside groups.” However, bills
devoted specifically to altering the limits have not been considered recently. Perhaps most
notably, H.R. 6286 (Cole) during the 111th Congress, and S. 1091 (Corker) and H.R. 3792
(Wamp) during the 110th Congress, would have eliminated existing caps on coordinated party
expenditures. On April 18, 2007, the Senate Committee on Rules and Administration held a
hearing on S. 1091; it was not subject to additional legislative action. H.R. 3792 was introduced
on October 10, 2007; it did not receive additional action.
Since that time, most proposals to alter existing coordinated party expenditures have been
components of other bills, particularly those devoted to public financing. Most recently, these
include H.R. 20 (Sarbanes), H.R. 268 (Sarbanes), H.R. 269 (Yarmuth), H.R. 270 (Price, N.C.),
and S. 2023 (Durbin), all introduced during the 113th Congress.
29 558 U.S. 310 (2010). For further discussion of Citizens United, see CRS Report R41045, The Constitutionality of
Regulating Corporate Expenditures: A Brief Analysis of the Supreme Court Ruling in Citizens United v. FEC, by L.
Paige Whitaker.
30 2 U.S.C. §441b.
31 See Cao v. FEC, 619 F.3d 410, 431 (5th Cir. 2010), cert. denied 131 S. Ct. 1718 (2011) (holding, among other things,
that in accordance with the Supreme Court’s decision in Colorado II, limits on coordinated party expenditures are
constitutional).
32 See Citizens United, 558 U.S. at 345 (quoting Buckley, 424 U.S. at 47).
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Coordinated Party Expenditures in Federal Elections: An Overview
Financial Overview and Analysis33
Although coordinated expenditures played a large role in party financial activity throughout the
1970s and 1980s, recent elections suggest that party reliance on coordinated expenditures is
changing. As Table 1 and Figure 1 (below) show, although the Colorado I decision permitted
parties to make unlimited independent expenditures during and after the 1996 cycle, those
expenditures remained relatively modest through 2002. From 1996 to 2002, total party
coordinated expenditures outpaced independent expenditures—often by large amounts.
Beginning in 2004, however, party spending shifted dramatically, with far more total independent
expenditures than coordinated expenditures. In 2004, the two major parties made more than four
times in independent expenditures what they did in coordinated expenditures. That allocation of
resources continued in 2006, when the parties spent more than six times on independent
expenditures as they did on coordinated expenditures. The trend also continued thereafter, albeit
in some cases less dramatically than in 2004. In 2012, the two major parties spent more than three
times on independent expenditures what they did in coordinated party expenditures
(approximately $254 million versus about $76 million). As the table also shows, at various points
since 1996, each major party has outspent the other in coordinated expenditures. For the most
part, however, Democrats and Republicans have allocated similar amounts to coordinated party
expenditures.
Table 1. National Party Coordinated and Independent Expenditures
Coordinated Expenditures
Independent Expenditures
Election
Cycle Democrat Republican Total
Democrat Republican Total
1996
$22,576,000 $30,959,151 $53,535,151 $1,495,090 $10,026,541 $11,521,631
1998 $18,643,156
$15,696,145
$34,339,301
$1,489,707
$263,646
$1,753,353
2000 $20,989,872
$29,598,965
$50,588,837
$2,310,175
$1,556,802
$3,866,977
2002 $7,057,291
$15,951,023
$23,008,314
$1,701,292
$1,944,116
$3,645,408
2004
$33,113,799 $29,101,396 $62,215,195 $176,491,696 $88,032,382 $264,524,078
2006
$20,694,359 $14,156,926 $34,851,285 $108,100,265 $115,646,387 $223,746,652
2008
$37,988,558 $31,952,985 $69,941,543 $156,191,039 $124,682,649 $280,873,688
2010
$24,907,052 $27,135,226 $52,042,278 $107,366,866 $76,138,018 $183,504,884
2012
$39,511,028 $36,307,810 $75,818,838 $113,752,700 $140,306,195 $254,058,896
33 Some of the data in this version of the report may vary from previously released FEC data. This discrepancy is due to
changes in the way in which the FEC calculates various receipts and disbursements in current statistical releases
compared with previous election cycles. In March 2014, the FEC adjusted the cited data table and affixed the following
explanation to the table: “To maintain consistency with how they had been calculated in prior years, the totals in this
table...were revised on March 27, 2014 to include transfers between party committees and transfers between party
committees’ federal and nonfederal accounts that had been inadvertently excluded from the original calculations, and to
exclude sums representing the Levin share of Federal Election Activity that had been inadvertently included in the
original calculations.” CRS takes no position on these changes and will continue to monitor the data for future
amendments.
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Coordinated Party Expenditures in Federal Elections: An Overview
Source: CRS analysis of FEC data in files accompanying “Table 1, National Party Financial Activity” in the
respective 24-month national-party financial activity summary for the listed election cycles, http://fec.gov/press/
campaign_finance_statistics.shtml.
Note: Individual party totals include expenditures from the Democratic National Committee, Democratic
Senatorial Campaign Committee, Democratic Congressional Campaign Committee, and state and local
Democratic committees; and Republican National Committee, National Republican Senatorial Committee,
National Republican Congressional Committee, and state and local Republican committees, as reflected in the
FEC data. The FEC data include only federal activity.
Figure 1. National Party Coordinated and Independent Expenditures
Republican Expenditures
Democratic Expenditures
$Millions
Coordinated Independent
Coordinated Independent
$200
$150
$100
$50
$0
1996
1998
2000
2002
2004
2006
2008
2010
2012
Election Cycle
Source: CRS analysis of FEC data in files accompanying “Table 1, National Party Financial Activity” in the
respective 24-month national-party financial activity summary for the listed election cycles, http://fec.gov/press/
campaign_finance_statistics.shtml.
Notes: Individual party totals include expenditures from the Democratic National Committee, Democratic
Senatorial Campaign Committee, Democratic Congressional Campaign Committee, and state and local
Democratic committees; and Republican National Committee, National Republican Senatorial Committee,
National Republican Congressional Committee, and state and local Republican committees, as reflected in the
FEC data. The FEC data include only federal activity.
One potential concern about lifting the caps on party coordinated expenditures could be that one
party would have an inherent advantage over the other. Recent fundraising totals suggest that the
historic fundraising gap between Democrats and Republicans has narrowed, although disparities
between the two parties still exist. As Table 2 and Figure 2 (below) show, local, state, and
national Republican party committees have accumulated more receipts than their Democratic
counterparts since 1996, as has generally occurred since at least the 1970s. Although an 88% gap
between Democratic and Republican receipts existed in 1996 ($416.5 million for Republicans
versus $221.6 million for Democrats), beginning in 2004, the two parties began to raise roughly
similar amounts. Despite a 24% Republican advantage in 2006 ($599 million versus $483.1
million), differences between the parties have been small since 2008. In 2012, the Democratic
and Republican parties both raised about $800 million. On their own, these data do not suggest
particular outcomes if caps on party coordinated expenditures were lifted, but they do indicate
that one party may not necessarily have a major total financial advantage over the other if the
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caps are lifted in the near future. Although the parties would not choose to spend all those funds
on coordinated party expenditures, the data suggest that they would likely be working with
roughly equal resources.
Table 2. Total Receipts of Democratic and Republican Party Committees
Election Cycle
Democratic Party Committees
Republican Party Committees
1996 $221,613,028
$416,513,249
1998 $159,961,869
$285,007,168
2000 $275,230,680
$465,840,139
2002 $217,245,185
$424,140,589
2004 $688,767,334
$782,410,369
2006 $483,141,404
$599,008,498
2008 $763,340,182
$792,867,579
2010 $618,065,814
$542,143,412
2012 $800,137,906
$803,531,878
Source: CRS analysis of FEC data in files accompanying “Table 1, National Party Financial Activity” in the
respective 24-month national-party financial activity summary for the listed election cycles, http://fec.gov/press/
campaign_finance_statistics.shtml.
Notes: Individual party totals include the Democratic National Committee, Democratic Senatorial Campaign
Committee, Democratic Congressional Campaign Committee, and state and local Democratic committees; and
Republican National Committee, National Republican Senatorial Committee, National Republican Congressional
Committee, and state and local Republican committees, as reflected in the FEC data. The FEC data include only
federal activity.
Figure 2. Total Receipts of Democratic and Republican Party Committees
$Millions
Total Rep. Receipts
Total Dem. Receipts
$900
$600
$300
$0
1996
1998
2000
2002
2004
2006
2008
2010
2012
Election Cycle
Source: CRS analysis of FEC data. Data for 2006-2012 appear in files accompanying “Table 1, National Party
Financial Activity” in the “2011-2012 Election Cycle Data Summaries through 12/31/12,” statistical summary,
http://fec.gov/press/summaries/2012/ElectionCycle/24m_NatlParty.shtml. Data for 1996-2004 appear in files
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accompanying “Table 1, National Party Financial Activity” in the respective 24-month national-party financial
activity summary, http://fec.gov/press/campaign_finance_statistics.shtml.
Notes: Individual party totals include the Democratic National Committee, Democratic Senatorial Campaign
Committee, Democratic Congressional Campaign Committee, and state and local Democratic committees; and
Republican National Committee, National Republican Senatorial Committee, National Republican Congressional
Committee, and state and local Republican committees, as reflected in the FEC data. The FEC data do not count
transfers among committees and include only federal activity.
For those who support lifting the caps on coordinated party expenditures, current limits impinge
on parties’ abilities to orchestrate unified campaigns with their candidates after the limits are
reached. Unrestricted coordinated party expenditures could shift party spending away from
independent expenditures, although each option would retain unique characteristics. Parties might
continue to choose independent expenditures if they wish to distance campaigns from what many
political professionals and some candidates view as necessary, but politically unpopular,
purchases (e.g., for political advertising attacking opponents).34 On the other hand, coordinated
expenditures would be more attractive for parties wishing to communicate freely with campaigns
about campaign-related spending. Raising or eliminating coordinated party expenditure limits
might also provide parties with additional resources to compete against independent expenditures
from super PACs or other “outside” groups.35 Additional coordinated expenditures could,
therefore, strengthen arguably weakening ties between parties and campaigns.
Proponents of limits on party coordinated expenditures contend that the caps reduce the amount
of money in politics. They also potentially prevent circumvention of individual contribution
limits by donors who may seek to indirectly support campaigns by making contributions to
political parties. (However, it should be noted that FECA already restricts “earmarked”
contributions.)36 For those who generally support regulating political money, lifting or raising the
caps on party-coordinated expenditures would likely be objectionable on principle, could appear
to undercut similar regulatory efforts adopted since the 1970s, and could go against public
sentiment generally favoring limiting the amount of money in politics.
Finally, revisiting coordinated party expenditure limits might also be relevant following an April
2014 U.S. Supreme Court decision in McCutcheon v. FEC. The McCutcheon case, which
concerned now-invalidated aggregate limits on contributions to political parties, is not centrally
related to coordinated party expenditures. However, post-McCutcheon, some might argue that
providing parties with increased limits (or none) on coordinated party expenditures is a logical
extension of their newfound ability to solicit donors who previously would have been unable to
contribute to as many party committees as they wished. Additional discussion of McCutcheon and
potential party fundraising implications appears in other CRS products.37
34 On relationships between campaign actors, see, for example, David A. Dulio, For Better or Worse? How Political
Consultants are Changing Elections in the United States (Albany: State University of New York Press, 2004); Paul S.
Herrnson, Congressional Elections: Campaigning at Home and in Washington (Washington: Congressional Quarterly
Press, 2004); and Robin Kolodny, Pursuing Majorities: Congressional Campaign Committees in American Politics
(Norman, OK: University of Oklahoma Press, 1998).
35 For additional discussion, see CRS Report R42042, Super PACs in Federal Elections: Overview and Issues for
Congress, by R. Sam Garrett.
36 2 U.S.C. §441a(a)(8).
37 See CRS Report R43334, Campaign Contribution Limits: Selected Questions About McCutcheon and Policy Issues
for Congress, by R. Sam Garrett; CRS Legal Sidebar WSLG873, Supreme Court Strikes Overall Limits on Campaign
Contributions in McCutcheon, by L. Paige Whitaker; and CRS Legal Sidebar WSLG842, McCutcheon and Its Potential
Impact on Campaign Finance Law, by L. Paige Whitaker.
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Author Contact Information
R. Sam Garrett
L. Paige Whitaker
Specialist in American National Government
Legislative Attorney
rgarrett@crs.loc.gov, 7-6443
lwhitaker@crs.loc.gov, 7-5477
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