Late Friday afternoon, the U.S. Supreme Court granted a stay of the Fourth Circuit’s decision setting aside the FCC Media Bureau’s guidance on entitlement to the lowest unit charge (“LUC”) for certain political ads placed on broadcast TV and radio. See our prior post about this issue here. Notably
Continue Reading Supreme Court Action Revives FCC Media Bureau’s Political Ad GuidanceCampaign Finance
Fourth Circuit Sets Aside FCC Media Bureau Guidance on Lowest Unit Charge; FCC Asks the Supreme Court to Step In
Posted in Campaign Finance
On August 25, 2026, a divided panel of the U.S. Court of Appeals for the Fourth Circuit set aside guidance by the FCC’s Media Bureau stating that two types of political advertising were entitled to the favorable “lowest unit charge” (“LUC”) rate: ads paid for as “party coordinated expenditures,” meaning…
Continue Reading Fourth Circuit Sets Aside FCC Media Bureau Guidance on Lowest Unit Charge; FCC Asks the Supreme Court to Step InEarly Post-NRSC Domino Falls: Minnesota Stops Enforcing Limits on Certain Party In-Kind Contributions
By Andrew Garrahan & Alex Langton on
Posted in Campaign Finance, State Law
State regulators are beginning to grapple with the implications of the Supreme Court’s recent decision in National Republican Senatorial Committee v. FEC (“NRSC”). Minnesota may have provided the first clear example of how the ruling could reshape state campaign finance regimes. On June 30, the Supreme Court struck…
Continue Reading Early Post-NRSC Domino Falls: Minnesota Stops Enforcing Limits on Certain Party In-Kind ContributionsSupreme Court Decision in National Republican Senatorial Committee v. Federal Election Commission Empowers Political Parties, Calls Other Restrictions into Question
In a major decision today, the Supreme Court in NRSC v. FEC struck down longstanding limits on “coordinated party expenditures” that restricted the amounts political parties could spend in coordination with federal candidates. With this decision, national party committees and the federal accounts of state parties can now spend unlimited…
Continue Reading Supreme Court Decision in National Republican Senatorial Committee v. Federal Election Commission Empowers Political Parties, Calls Other Restrictions into QuestionCovington Launches Election Year Toolkit
As the election season intensifies, companies face a rapidly evolving landscape of regulatory, compliance, and reputational considerations. With heightened scrutiny on political engagement, lobbying, campaign finance, and communications, organizations must be prepared to navigate complex and fast-moving legal requirements.
Drawing on our deep experience in election and political law, public…
Continue Reading Covington Launches Election Year ToolkitThe 6 Top Compliance Mistakes by Corporations in an Election Year
By Andrew Garrahan & Kimberly Railey on
Posted in Campaign Finance
An election year brings ample opportunities for corporations to participate in the political process, and the current political environment can create enormous pressures to do so. But with these opportunities and pressures come legal risks and compliance burdens. Given the differing and complex rules across jurisdictions, companies should be aware…
Continue Reading The 6 Top Compliance Mistakes by Corporations in an Election YearDon’t Forget Your California Major Donor Reports!
By Andrew Garrahan & Addie Zinsner on
Posted in Campaign Finance, State Law
With redistricting, the “billionaire tax” and other ballot measures, and heated gubernatorial and other races, contributors are giving huge amounts of money this year in California state and local elections. California has a complex campaign finance system, and it can be easy to miss some of the requirements. Key among…
Continue Reading Don’t Forget Your California Major Donor Reports!Covington’s Guide to Ballot Measures
By Robert Kelner, Derek Lawlor, Andrew Garrahan & Lauren Cox on
More than one billion dollars were spent in 2024 elections supporting or opposing state and local ballot measures. With high-profile and contentious issues expected to be on the ballot, such as congressional redistricting, AI regulation, minimum wage increases, and more, that number promises to be even larger in 2026. As…
Continue Reading Covington’s Guide to Ballot MeasuresCorporate and Industry “Mega PACs”: The Next Frontier for Super PACs
By Derek Lawlor, Andrew Garrahan & Kimberly Railey on
Posted in Campaign Finance
Since the landmark Citizens United decision in 2010, super PACs have become a fixture of U.S. political campaigns. But despite the initial anticipated boom in corporate influence in elections, most super PAC funding to date has come from wealthy individuals, closely-held corporations, and nonprofits, not from large for-profit corporations.
However…
Continue Reading Corporate and Industry “Mega PACs”: The Next Frontier for Super PACsForming and Operating Super PACs: A Practical Guide for Political Consultants in 2026
By Derek Lawlor, Andrew Garrahan & Kimberly Railey on
Posted in Campaign Finance
In the 2024 election cycle, super PACs spent a reported $2.7 billion at the federal level, up from roughly $1.4 billion in 2022. And in 2025, super PACs poured tens of millions into state and local races, including the New Jersey gubernatorial race and the New York City mayoral…
Continue Reading Forming and Operating Super PACs: A Practical Guide for Political Consultants in 2026