States that wish to limit campaign contributions may do so only by showing an important state interest in combating actual quid pro quo corruption or its appearance. For many years, courts gave actual and apparent corruption a broad definition, but the last decade of Supreme Court rulings have narrowed it. In Lair v. Motl, the United State District Court for the State of Montana was presented with the question of whether Montana had an important state interest in combating quid pro quo corruption and whether its campaign contribution limits were closely drawn to that end. The court had already answered this question before. But here, the district court had the challenging task of distinguishing acceptable state interests in a post-Citizens United v. FEC world.
Dillon Haskell, Case Note, Lair v. Motl: A Step Back in Montana’s Fight Against Corruption, 78 Mont. L. Rev. Online 15, https://scholarship.law.umt.edu/mlr_online/vol78/iss1/3.