Thompson v. Hebdon

Thompson v. Hebdon, 589 U.S. ___ (2019), was a United States Supreme Court case challenging the constitutionality of Alaska’s low individual campaign contribution limits. Alaska law limited individual contributions to candidates for the state house and senate to $500 per election. Plaintiffs David Thompson, Aaron Downing, and Jim Crawford argued that these limits were so low that they violated the First Amendment by preventing meaningful political speech and association. The United States Court of Appeals for the Ninth Circuit had upheld the limits, but the Supreme Court granted certiorari. In a per curiam decision, the Court vacated the Ninth Circuit’s judgment and remanded the case. The Supreme Court directed the lower court to reexamine the limits under the framework established in Randall v. Sorrell, which held that extremely low contribution limits can unconstitutionally burden free speech, even when justified by anti-corruption interests.

The Supreme Court of the United States issued a per curiam opinion vacating the judgment of the Ninth Circuit and remanding the case for further proceedings consistent with the Court’s instructions. The lower court was ordered to reconsider the Alaska contribution limits in light of Randall v. Sorrell, which struck down Vermont’s extremely low limits and requires courts to assess whether such limits prevent candidates from amassing the resources necessary for effective advocacy.

Whether Alaska’s individual campaign contribution limits of $500 per election for state legislative candidates violated the First Amendment's free speech and association guarantees, and whether the Ninth Circuit erred by failing to properly apply the precedent set in Randall v. Sorrell that requires close scrutiny of contribution limits that are too low to permit effective political communication.

The decision reinforced that campaign contribution limits, even those enacted to combat corruption, can be unconstitutional if set excessively low. It clarified that lower courts must rigorously compare challenged limits with those previously invalidated, particularly the limits in Randall v. Sorrell. The ruling signaled that states with very low contribution caps might face renewed First Amendment challenges, emphasizing that political speech requires breathing room and that arbitrarily low ceilings on giving can impermissibly burden democratic participation.