Thompson v. Hebdon, 589 U.S. 1

Alaska law caps individual contributions to candidates and election-oriented groups at $500 per year; the limit has not changed since 1996.
Petitioners (Alaska residents) gave the statutory maximum in 2015, sought to give more, and sued the Alaska Public Offices Commission arguing the limits violate the First Amendment.
The District Court upheld the limits; the Ninth Circuit affirmed, applying its precedent that a contribution limit survives if it furthers a "sufficiently important" state interest and is "closely drawn."
The Ninth Circuit acknowledged Citizens United and McCutcheon narrowed permissible state interests to preventing quid pro quo corruption or its appearance, but relied on circuit precedent (Eddleman) and declined to apply Randall v. Sorrell.
The Supreme Court granted certiorari, vacated the Ninth Circuit judgment, and remanded for reconsideration in light of Randall because Alaska’s limits are unusually low, uniform across offices, and not indexed for inflation (raising Randall’s "danger signs").
Justice Ginsburg concurred in the remand, noting potential special justifications for Alaska’s low limits (small legislature; economy concentrated in oil and gas) that the lower courts should consider.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Alaska’s $500 individual-to-candidate limit under the First Amendment	$500 is too low and burdens political speech/association and challengers’ ability to campaign	Limit serves to prevent corruption and appearance of corruption; is narrowly drawn	Supreme Court vacated and remanded for reconsideration in light of Randall (no merits decision)
Validity of $500 individual-to-group (anti-circumvention) limit	Plaintiffs: group limit also restricts speech by blocking routing of support to candidates	State: group limit prevents circumvention of candidate limits and combats corruption	Ninth Circuit upheld; Supreme Court remanded for reconsideration in light of Randall
Whether Ninth Circuit should apply its Eddleman standard or the Randall analysis	Plaintiffs: Randall controls review of unusually low, non-indexed, uniform limits	State: Ninth Circuit precedent governs; Citizens United/McCutcheon limit permissible state interests	Supreme Court instructed remand so the court of appeals can revisit the case taking Randall into account
Whether Alaska’s factual justifications suffice to support the low limits	Plaintiffs: no special justification shown to permit such low limits	State: Alaska’s small legislature and oil/gas–dependent economy create heightened corruption risk	Remand ordered for lower court to evaluate whether Alaska’s "special justifications" (if any) sustain the limits

Citizens United v. Federal Election Comm’n, 558 U.S. 310 (2010) (limits permissible only to prevent quid pro quo corruption or its appearance)
McCutcheon v. Federal Election Comm’n, 572 U.S. 185 (2014) (reaffirmed narrowing of legitimate state interests to corruption/appearance)
Randall v. Sorrell, 548 U.S. 230 (2006) (plurality invalidated very low per-election contribution limits and identified "danger signs")
Nixon v. Shrink Missouri Government PAC, 528 U.S. 377 (2000) (upheld the lowest contribution limit previously sustained by Court)
Montana Right to Life Assn. v. Eddleman, 343 F.3d 1085 (9th Cir. 2003) (Ninth Circuit standard requiring more than mere conjecture to justify limits)
Thompson v. Dauphinais, 217 F. Supp. 3d 1023 (D. Alaska 2016) (district court upheld Alaska’s limits)
Thompson v. Hebdon, 909 F.3d 1027 (9th Cir. 2018) (Ninth Circuit affirmed under its precedent; declined to follow Randall)