Amicus Curiae Brief of
Campaign Legal Center

A. The Act Is Supported by Valid—and Compelling—Anticorruption Interests that the District Court Failed to Credit

Concerns about the corruptive potential of large financial contributions benefiting candidates—regardless of whether those funds are ultimately used for independent expenditures—are neither "novel nor implausible." Shrink Missouri, 528 U.S. at 391. As the Supreme Court has noted, "there is little reason to doubt that sometimes large contributions will work actual corruption of our political system, and no reason to question the existence of a corresponding suspicion among voters." Id. at 395.

Nevertheless, although the anticorruption interests animating the Act have long been recognized by the Supreme Court as both "legitimate and compelling," FEC v. Nat'l Conservative PAC, 470 U.S. 480, 496 (1985), the district court refused to credit them here. Instead, it doubled down on the faulty reasoning of SpeechNow and its nonbinding analogues from other Circuits, which collectively assumed that if "independent expenditures do not corrupt or give the appearance of corruption as a matter of law, then the government can have no anti-corruption interest in limiting contributions to" independent expenditure-only committees. SpeechNow, 599 F.3d at 696; see JA350-53. See also, e.g., Wis. Right to Life State PAC v. Barland, 664 F.3d 139, 154 (7th Cir. 2011); Texans for Free Enter. v. Tex. Ethics Comm'n, 732 F.3d 535, 537-38 (5th Cir. 2013); Republican Party of N.M. v. King, 741 F.3d 1089, 1103 (10th Cir. 2013); N.Y. Progress & Prot. PAC v. Walsh, 733 F.3d 483, 487 (2d Cir. 2013); Alaska Pub. Offs. Comm'n v. Patrick, 494 P.3d 53, 58 (Alaska 2021).

Notwithstanding this apparent consensus in the lower appellate courts, in all of the Supreme Court's decisions involving contribution limits, "[t]he importance of the governmental interest in preventing [corruption] has never been doubted." FEC v. Beaumont, 539 U.S. 146, 154 (2003) (second alteration in original) (citation omitted). Indeed, this Court today is presented with a much more compelling anticorruption case for limiting contributions to super PACs than was the D.C. Circuit fifteen years ago in SpeechNow, where there was no practical experience with super PACs and the plaintiff group in no way resembled how the median super PAC now operates. The plaintiffs in SpeechNow were a group of individuals who formed an unincorporated nonprofit association that lacked any ties to parties or candidates and planned to spend in support of multiple candidates. 599 F.3d at 689-90. In contrast, today, political operatives from candidates' inner circles routinely organize and run sophisticated single-candidate super PACs—a reality that significantly compounds the risk of quid pro quo corruption. See, e.g., Fred Wertheimer, The Case for Ending Individual-Candidate Super PACs, Democracy 21 (Feb. 26, 2019), https://perma.cc/W2CL-V5EJ.

And while Citizens United v. FEC, 558 U.S. 310 (2010), provided the impetus for SpeechNow and similar lower court decisions, it did not address contribution limits or alter the longstanding framework for their review. Both before and after Citizens United, the Supreme Court has consistently subjected contribution limits to lesser scrutiny than expenditure ceilings because "the transformation of contributions into political debate involves speech by someone other than the contributor." Buckley v. Valeo, 424 U.S. 1, 21 (1976) (per curiam); see, e.g., McCutcheon v. FEC, 572 U.S. 185, 218 (2014) (applying closely drawn scrutiny to aggregate limit); Beaumont, 539 U.S. at 161 (upholding federal corporate contribution ban under closely drawn standard); Buckley, 424 U.S. at 20-23, 25. See also, e.g., Cal. Med. Ass'n v. FEC, 453 U.S. 182, 196 (1981) (describing contributions to a PAC as "speech by proxy" that is "not . . . entitled to full First Amendment protection").

Further, the Buckley framework and its "relatively complaisant review," Beaumont, 539 U.S. at 161, applies to the analysis of a contribution limit regardless of how the recipient committee ultimately spends the money. So when the Supreme Court analyzed the federal ban on spending so-called "soft money" in McConnell v. FEC, 540 U.S. 93 (2003), it treated that "mechanism" as a contribution limit rather than a spending limit (and thus applied a lesser form of scrutiny) because "large soft-money contributions to national parties are likely to create actual or apparent indebtedness on the part of federal officeholders, regardless of how those funds are ultimately used." 540 U.S. at 138-39, 155 (emphasis added).

The Court has twice summarily affirmed that reasoning in later challenges to the soft-money restrictions, most recently in Republican Party of Louisiana v. FEC, 137 S. Ct. 2178 (2017) (mem.) (affirming three-judge federal court decision finding that contributions to political parties can corrupt even when the parties' expenditures do not). As Judge Srinivasan explained in his opinion for the three-judge panel, "the inducement occasioning the prospect of indebtedness on the part of a federal officeholder is not the spending of soft money by a political party," but "instead comes from the contribution of soft money to the party in the first place." 219 F. Supp. 3d 86, 97 (D.D.C. 2016). The same principle holds here. Like other contribution limits, the Act does not "in any way limit[ ] the total amount of money [committees] can spend," McConnell, 540 U.S. at 139, but "merely" requires them "to raise funds from a greater number of persons." Id. at 136 (citing Buckley, 424 U.S. at 21-22).

Experience in the years since SpeechNow only further exposes the errors of that decision and its progeny, which did not consider or anticipate the mounting evidence that large contributions to super PACs do facilitate opportunities for corrupt quid pro quos. See infra Part I.B. Nor did most of those courts have the benefit of recent empirical research indicating that the explosion of multimillion-dollar contributions to super PACs creates the appearance of corruption and erodes public confidence in the democratic process. See infra Part II.

Therefore, the district court erred in assuming, following "the logic" of Citizens United and SpeechNow, JA353, that any factual record evincing the corruptive potential of super PAC contributions would be insufficient as a matter of law to sustain the Act. Assessing whether a given contribution limit is supported by valid and sufficiently weighty anticorruption interests is part and parcel of the constitutional analysis under the applicable "closely drawn" standard of scrutiny. Whether political contributions pose a risk of corruption is a question of legislative fact, and courts tasked with answering it should consult the full range of relevant sources, including controlling precedent, the records in other cases, and available empirical studies and recorded experience. See, e.g., Ognibene v. Parkes, 599 F. Supp. 2d 434, 448 (S.D.N.Y. 2009) ("[L]egislative facts" are to be considered "in determining whether a reasonable person would believe that corruption or the potential for corruption exists."), aff'd, 671 F.3d 174 (2d Cir. 2011). Maine's evidence was owed a fuller consideration.

The evidentiary record thoroughly substantiates Maine's concerns about corruption stemming from large contributions to super PACs, and refutes the proposition endorsed below that Maine's asserted anticorruption interests are categorically "not enough" to justify its adoption of a $5,000 limit. JA354.

B. The Corruptive Potential of Unlimited Contributions to Super PACs Is Amply Borne Out by the Empirical Record and Experience Since 2010

Since 2010, real-world political practice has disproven the central factual premise on which SpeechNow and its progeny have rested. SpeechNow treated contributions to independent spenders as too attenuated from candidates to pose the risk of quid pro quo corruption or its appearance, reasoning that because Citizens United held that independent expenditures cannot result in corruption, donations to entities that make only independent expenditures must likewise be harmless. See 599 F.3d at 696. But that assumption has now been overtaken by evidence.

Numerous high-profile cases, including criminal prosecutions, now reveal that contributions to super PACs can and frequently do constitute the "quid" in a corrupt quid pro quo transaction between a super PAC donor and public official. This is true even though contributions to super PACs do not directly line a public official's pockets or campaign coffers; evidence shows that candidates nevertheless value super PAC contributions enough to trade them for official acts. Candidates solicit super PAC contributions precisely because they believe that such contributions bolster their own electoral prospects. And donors route their payments through super PACs precisely because the magnitude of those sums—often millions of dollars—would be unlawful if made as direct campaign contributions to the candidate (currently limited to $3,500 per election at the federal level).

This dynamic is amplified by the fact that donors may coordinate their contributions to super PACs with the candidates they seek to support. As Appellants emphasize, Citizens United treated independent expenditures as non-corrupting only because they are, "by definition," not coordinated with a candidate. See Equal Citizens Opening Br. 17 (quoting Citizens United, 558 U.S. at 360). But contributions to super PACs are not subject to any comparable ban on coordination—candidates may even solicit them directly (within applicable hard-money limits at the federal level, see 52 U.S.C. § 30125)—so they can be traded for official acts. See Equal Citizens Opening Br. 13-14, 30-31. As one study of super PAC contributions observed, "[c]ritics of the SpeechNow ruling and its descendants have rightly argued that [the ruling's] analysis ignores the ability of contributors of unlimited funds to [super PACs] to communicate with candidates benefiting from those donations and thereby turns a blind eye to the danger of quid pro quo corruption and its appearance."

Federal bribery cases in the past decade show conclusively that super PAC contributions can—and do—serve as the payable "quid" in an illicit bargain. Courts hearing these cases have refused to dismiss the indictments based on arguments invoking SpeechNow, recognizing that a super PAC donation can be the basis for corruption even when the super PAC purports to spend that money independently.

United States v. Menendez

Federal prosecutors alleged that Senator Robert Menendez solicited approximately $300,000 earmarked for a super PAC aligned with his reelection in exchange for intervening with federal regulators on behalf of a donor. United States v. Menendez, 132 F. Supp. 3d 635, 640 (D.N.J. 2015). Senator Menendez moved to dismiss on the theory adopted in SpeechNow: that super PAC contributions are incapable of corruption because they fund "independent" expenditures. See id. at 639-40. The court rejected that argument, holding that a jury could find that Menendez "placed value, albeit subjective, on the earmarked donations" to the super PAC. Id. at 640. The indictment also alleged an "explicit quid pro quo." Id. at 643. The court later reaffirmed that a jury could convict Menendez of bribery based on super PAC contributions because "there was ample evidence available from which it could conclude either that Menendez placed subjective value on [the] contributions, or that Menendez (or his agents) solicited" the contributions. United States v. Menendez, 291 F. Supp. 3d 606, 622 (D.N.J. 2018).

United States v. Lindberg

The prosecution of North Carolina businessman Greg Lindberg confirms the same pattern. Lindberg and associates allegedly sought the removal of a state insurance regulator hostile to his interests and promised to put $1.5 million into a super PAC supporting the commissioner's reelection. United States v. Lindberg, No. 5:19-cr-22, 2020 WL 520948, at *2 (W.D.N.C. Jan. 31, 2020) (unpublished). When defendants argued that such contributions are constitutionally noncorrupting, the court rejected the argument and declined to dismiss the indictment. See id. at *7 n.6. Lindberg was convicted in May 2024.

United States v. Householder

In 2020, federal prosecutors charged former Ohio House Speaker Larry Householder and his associates with operating a racketeering conspiracy built around bribe payments routed to a super PAC. According to the indictment, the alleged bribe was a stream of roughly $60 million that electric utility FirstEnergy quietly paid to Generation Now, a dark-money nonprofit controlled by Householder's network. This money was then used to fund a Householder-aligned super PAC that spent heavily on advertising to elect Householder and candidates loyal to him, which in turn helped Householder to be elected speaker in 2019. See United States v. Householder, No. 1:20-CR-77, 2023 WL 24090 (S.D. Ohio Jan. 3, 2023) (unpublished). The money funded advertising and electioneering almost entirely to maintain Householder's political power and was structured as a continuing pipeline of political support exchanged for legislative duty. See id. at *1, *5-6. The court's refusal to dismiss the indictment, see id., and Householder's later conviction, see Judgment, United States v. Householder, No. 1:20-cr-77 (S.D. Ohio July 6, 2023), ECF No. 288, confirm that quid pro quo corruption does not require officials to pocket personal checks—just to direct vast political resources that they perceive will keep them in office.

United States v. Vázquez-Garced

Similarly, in the prosecution of former Puerto Rico Governor Wanda Vázquez-Garced, the indictment alleged that the scheme began while Bancrédito—an international bank owned by Venezuelan financier Julio Martín Herrera Velutini—was under examination by Puerto Rico's Office of the Commissioner of Financial Institutions ("OCIF"). Herrera Velutini allegedly sought to defuse that scrutiny by offering, through intermediaries, to provide major financial backing for Vázquez-Garced's 2020 reelection bid if she would remove the sitting OCIF commissioner and replace him with someone favorable to his bank's interests. See Indictment at 7-13, United States v. Vázquez-Garced, No. 3:22-CR-342 (D.P.R. Aug. 4, 2022). Prosecutors allege that Vázquez-Garced accepted the bargain, ultimately forcing out the incumbent regulator and installing a former consultant to Bancrédito. See id. at 14-17. The indictment further alleges that Herrera Velutini conveyed his willingness to form and finance a super PAC supporting her campaign as part of the same quid pro quo. See id. at 17-21; see also Frances Robles, Former Puerto Rico Governor Arrested on Corruption Charges, N.Y. Times (Aug. 4, 2022), https://www.nytimes.com/2022/08/04/us/puerto-rico-wanda-vasquez-arrest.html (reporting DOJ allegation that Herrera "then formed a political action committee for Ms. Vázquez"). When Vázquez-Garced later lost her primary, Herrera Velutini allegedly shifted strategy, attempting to bribe the eventual winner—current Governor Pedro R. Pierluisi—by offering super PAC support in exchange for favorable regulatory treatment of Bancrédito. See Robles, supra.

United States v. Parnas

In 2019, Lev Parnas and Igor Fruman funneled hundreds of thousands of dollars to America First Action, a high-dollar super PAC supporting President Trump, for the express purpose of "obtain[ing] access to exclusive political events and gain[ing] influence with politicians." They routed a $325,000 contribution through a shell LLC to disguise the true source of the funds and another $15,000 to a second super PAC. Prosecutors alleged—and trial evidence confirmed—that the scheme's purpose was to "buy potential influence with candidates, campaigns, and the candidates' governments." Sealed Indictment at 2, United States v. Parnas, 1:19-cr-00725 (S.D.N.Y. Oct. 9, 2019).

Zekelman Industries (MUR 7613)

In 2022, the FEC imposed one of the largest fines in its history—$975,000—against entities controlled by Canadian billionaire Barry Zekelman for directing $1.75 million to the pro-Trump super PAC America First Action. See FEC, Factual & Legal Analysis and Conciliation Agreement (MUR 7613) (Zekelman Industries, Inc.), https://perma.cc/A2SP-Q9JS. The payoff was not subtle: shortly after the contribution, Zekelman was invited to a private dinner to discuss trade policy affecting his steel empire, which was soon followed by the administration imposing caps on steel imports from Zekelman competitors, like South Korea. See CLC, New York Times Report on Canadian CEO Barry Zekelman Prompts Two CLC Complaints (May 24, 2019), https://perma.cc/ED2E-H2KK.

United States v. Azano Matsura

In 2016, a Mexican businessman and foreign national, Jose Susumo Azano Matsura, was sentenced to three years in federal prison after funneling $500,000 in illegal contributions to San Diego mayoral candidates via straw donors in an attempt to buy support for a waterfront development project and access to political figures. $100,000 of the funds were routed through a super PAC created by Matsura and his associates to support the campaign of Bonnie Dumanis for Mayor. Matsura worked with a campaign consultant and a former San Diego police detective to effect the contributions; both were also charged in the scheme.

When viewed collectively, these cases demonstrate that super PAC contributions now routinely serve as the quid in corrupt, quid pro quo arrangements. Fifteen years ago, the D.C. Circuit in SpeechNow was not faced with the current reality of sophisticated super PACs acting as conduits for corruption. See supra at 6. The premise of SpeechNow—that contributions to independent spenders would be too far removed or too "independent" to be or appear corrupt—has been disproven. Unlimited sums create a functional marketplace for political favors in which donors trade large contributions for expected official benefit.

Recent conduct underscores just how far from reality SpeechNow's factual premise has drifted. Elon Musk's relationship with the administration is paradigmatic. Musk spent nearly $300 million to support President Trump's 2024 campaign—funds routed primarily through a pro-Trump super PAC, America PAC—before being installed as the head of a newly created "U.S. DOGE Service," where he exercised direct authority over agencies with regulatory jurisdiction over his own companies. See CLC, Trump's Corrupt Transactions: How the 47th President Has Brazenly Traded Official Benefits for Personal and Political Gain at 3 (Oct. 15, 2025), https://perma.cc/6N7V-8QPR. The public record reflects subsequent regulatory and contracting benefits to Musk's businesses, including Starlink, Tesla, and xAI. See id. Longtime Trump donor Linda McMahon likewise contributed more than $20 million to the pro-Trump super PAC Make America Great Again Inc. between late 2023 and 2024, before being named Secretary of Education. See id. at 4. In a similar vein, hedge fund executive Scott Bessent gave $1.4 million to Trump-affiliated super PACs and was promptly tapped to serve as Secretary of the Treasury. See id.

The same pattern extends to clemency decisions. For example, Paul Walczak received a presidential pardon shortly after his mother contributed $1 million at a MAGA Inc. fundraising dinner—an event tied to super PAC financing—and the pardon application expressly invoked that contribution. See id. at 11. These are not post hoc favors granted to supportive allies; they are official acts temporally and causally tethered to specific, seven- and eight-figure super PAC contributions. That linkage is the precise quid pro quo pattern SpeechNow and its descendants have deemed impossible. See 599 F.3d at 694.

Because the record now shows that unlimited super PAC contributions have become vehicles for trading official action, limits on those contributions should be permissible as the very kind of safeguard the Supreme Court has long recognized as essential to preventing the sale of public office.

A. Preventing the Appearance of Corruption Is a Compelling Governmental Interest in Its Own Right

The Supreme Court has repeatedly explained that preventing the appearance of corruption is a compelling governmental interest that can independently support campaign finance legislation:

Shrink Missouri, 528 U.S. at 390 (quoting United States v. Mississippi Valley Generating Co., 364 U.S. 520, 562 (1961)). As the Court has long recognized, avoiding the appearance of corruption is "[o]f almost equal concern as the danger of actual quid pro quo arrangements," and "the avoidance of the appearance of improper influence 'is also critical . . . if confidence in the system of representative Government is not to be eroded to a disastrous extent.'" Buckley, 424 U.S. at 27 (quoting CSC v. Letter Carriers, 413 U.S. 548, 565 (1973)). Indeed, "[t]his interest exists even where there is no actual corruption, because the perception of corruption, or of opportunities for corruption, threatens the public's faith in democracy." Ognibene v. Parkes, 671 F.3d 174, 186 (2d Cir. 2011).

These campaign finance holdings are consistent with the Supreme Court's other decisions involving the integrity of the nation's system of self-government and the essential role of public confidence in that system. See, e.g., Crawford v. Marion Cnty. Election Bd., 553 U.S. 181, 197 (2008) (recognizing that "public confidence in the integrity of the electoral process . . . encourages citizen participation in the democratic process") (internal quotation marks and citations omitted); Purcell v. Gonzalez, 549 U.S. 1, 4 (2006) ("Confidence in the integrity of our electoral processes is essential to the functioning of our participatory democracy."). As one scholar has observed, "[a]ppearances drive social trust, democratic legitimacy, and the constitutional stability of government. Legitimacy also facilitates voluntary compliance with the laws made under a political regime." Christopher T. Robertson et al., The Appearance and the Reality of Quid Pro Quo Corruption: An Empirical Investigation, 8 J. of Legal Analysis 375, 378 (2016) (citations omitted), available at https://academic.oup.com/jla/article/8/2/375/2502553.

The Supreme Court has similarly recognized the importance of appearances in cases concerning the judicial branch and the intersection of judicial impartiality and campaign finance. In Caperton v. A.T. Massey Coal Co., Inc., 556 U.S. 868 (2009), the Court found a due process violation when a West Virginia State Supreme Court Justice failed to recuse himself from a case in which one of the parties had spent exorbitant amounts in support of the Justice's campaign. The Court found that the public's perception of the judiciary is "a vital state interest" and explained that judicial codes "are the principal safeguard against judicial campaign abuses that threaten to imperil public confidence in the fairness and integrity of the nation's elected judges." Id. at 889 (internal quotation marks and citation omitted). And in Williams-Yulee v. Florida Bar, 575 U.S. 433, 453 (2015), the Court gave broad discretion to the legislature when the decision held that "Florida ha[d] reasonably determined that personal appeals for money by a judicial candidate inherently create an appearance of impropriety that may cause the public to lose confidence in the integrity of the judiciary."

B. The Public's Perception of Corruption Directly Affects the Strength and Vitality of American Democracy

The Supreme Court has correctly understood that the public's perception of corruption can have a deep and consequential effect in our system of democratic self-government. Campaign finance regulation is a key bulwark supporting the strength of that system; indeed, a growing body of empirical evidence indicates that our underregulated campaign finance system has contributed to a steep decline in the public's faith in government. Anticorruption measures like the Act are thus all the more essential—because they counter the widespread perception that American democracy is for sale.

Especially during the past decade, as campaign finance law has been further deregulated, the public's perception of corruption has continued to grow and its confidence in government's fairness and integrity has plummeted. When a demographically representative study in 2014 tested the American population's attitude on specific campaign finance issues, the highly statistically significant results indicated that "citizens experience a decrease in their faith in democracy as the magnitude of reported election campaign contributions from organizations increases." Rebecca L. Brown & Andrew D. Martin, Rhetoric and Reality: Testing the Harm of Campaign Spending, 90 N.Y.U. L. Rev. 1066, 1089 (2015). And citizens "experience a greater decrease in their faith in democracy based on evidence of reelection campaign expenditures on behalf of a candidate, when those expenditures are coordinated with the candidate's campaign, as compared with when the expenditures are truly independent." Id.

As Professors Spencer and Theodoridis have summarized, "[n]ationally representative surveys report that most Americans believe corruption is widespread throughout the government and that campaign contributors have a 'great deal' of influence over public policy decisions. . . . Survey respondents also report that contributions from corporations and unions are more corrupting than contributions from individuals." Douglas M. Spencer & Alexander G. Theodoridis, "Appearance of Corruption": Linking Public Opinion and Campaign Finance Reform, 19 Election L. J. 510, 510-11 (2020) (citations omitted).

Similarly, the Brennan Center for Justice has shared the following results of a national survey:

Brennan Ctr. for Justice, National Survey: Super PACs, Corruption, and Democracy (2012) (citations omitted), https://perma.cc/X6UJ-GJQ9.

Other recent scholarship has shown that "perceived corruption of standard campaign practices is by no means limited to political cynics, experts, partisans, or any other narrow grouping," but rather "is a super-majority judgment of the American citizenry." Matthew DeBell & Shanto Iyengar, Campaign Contributions, Independent Expenditures, and the Appearance of Corruption: Public Opinion vs. the Supreme Court's Assumptions, 20 Election L. J. 286, 297 (2021) (reporting a "relative invariance in the relationship between perceived corruption and political characteristics"). After testing several hypotheses about contributions, independent expenditures, and the perceptions of corruption they may create, the study found that "[p]erceptions of corruption increase consistently (monotonically) with the amount of money contributed or spent," and suggested that "current campaign finance laws may contribute to reduced trust in government and lower voter turnout." Id. at 296, 297.

Although Buckley recognizes that "laws making criminal the giving and taking of bribes deal with only the most blatant and specific attempts of those with money to influence governmental action," 424 U.S. at 27-28, the relevant empirical research suggests that the public's perception of quid pro quo corruption is quite broad. For example, in one pair of studies involving jury simulations and fact patterns "designed to mimic ubiquitous behavior that virtually any of the 535 Members of Congress engage in every day . . . the vast majority of [the mock] grand jurors were willing to indict such everyday behavior under the federal bribery statute," even though much of the described behavior is likely legal under current law. Robertson, Appearance and Reality, 8 J. of Legal Analysis at 380. To deter the kind of cynicism that can erode participation in and support for democratic governance, this Court should adopt a definition of the appearance of quid pro quo corruption that accords with the public's actual attitudes.

C. Maine's Interest in Avoiding the Appearance of Corruption Is Confirmed by the Evidentiary Record

In addition to the general empirical literature supporting Maine's interest in preventing perceived quid pro quo corruption, the Act also demonstrably effectuates that goal. The evidentiary record is replete with support for the proposition that limiting contributions to super PACs prevents apparent corruption, and confirms that Maine's limit is well tailored to that vital interest.

Perhaps most notably, the record includes expert testimony validating that the Act prevents apparent corruption. Employing vignette-based survey research methodology, Equal Citizens's expert found robust empirical support for several key propositions, including that contributions to super PACs foster the appearance of corruption; that "the amount of money matters"; and that perceptions of corruption spike "dramatic[ally]" at and above the precise level at which Maine's contribution limit is set ($5,000). JA205.

In one experiment, the study not only "found a clear relationship between the amount of money contributed and perceived likelihood that the elected official would sell a policy outcome," but also demonstrated that "$5,000 appears to be an inflection point in perceptions of quid pro quo corruption." JA205-206. In a second experiment simulating how the existence or absence of the contribution limit would affect perceptions of corruption, the researchers found that "a $5,000 cap on [super PAC] contributions has a significant and substantial effect on perceptions of quid pro quo corruption and that the cap supports broader perceptions of democratic legitimacy and effectiveness." JA210.

That the Act was adopted by Maine voters directly via citizen-initiated legislation is a particularly clear indication of public sentiment. In Shrink Missouri, which likewise considered contribution limits voters approved by statewide ballot measure, the Supreme Court noted that "the statewide vote . . . certainly attested to the perception relied upon here: [A]n overwhelming 74 percent of the voters of Missouri determined that contribution limits are necessary to combat corruption and the appearance thereof." 528 U.S. at 394 (internal quotation marks omitted). Considering this and other evidence, the Court concluded that "this case does not present a close call" as to whether Missouri met its "evidentiary obligation." Id. at 393. Here, too, the Act garnered a record-breaking number of votes and passed with an overwhelming 74.9% margin of victory, JA156, demonstrating that the vast majority of Maine voters perceive large contributions to super PACs as a serious problem in need of correction. That "certainly attest[s] to the perception [of corruption] relied upon here." 528 U.S. at 394.