ABSTRACT

In McConnell v. Federal Election Commission, 124 S. Ct. 619, the US Supreme Court upheld the Bipartisan Campaign Finance Reform Act of 2002, popularly known as the McCain-Feingold Act. This law imposed new limits on how money may be used by individuals and some groups to influence elections. McConnell eventually secured his name atop the consolidated litigation, which featured a list of eighty-four plaintiffs representing diverse political viewpoints, including the National Rifle Association, the American Civil Liberties Union, the American Federation of Labor with the Congress of Industrial Organizations, and the National Right to Work Com-mittee. Prior to McConnell, the Court had insisted that only the tangible result of the legislative process-a vote in favor of friendly legislation, a regulatory exemption, or a pork-barrel project, for example-triggered the possibility of corruption. The language of McConnell bears the hallmarks of Justice Stevens's twenty-seven years of frustration over the Court's campaign finance decisions.