Campaign Legal Center v. FEC (26-1559) seeks to vacate Advisory Opinion 2024-01

On May 6, 2026, the Campaign Legal Center (plaintiff) filed suit against the Commission in the U.S. District Court for the District of Columbia. Plaintiff alleges that Advisory Opinion (AO) 2024-01 unlawfully permits federal candidates to outsource and conceal campaign spending through coordinated canvassing financed by outside groups. Plaintiff seeks a declaration that the Commission’s approval of AO 2024-01 is contrary to law and arbitrary and capricious, and violates the Federal Election Campaign Act (the Act) and the Administrative Procedure Act. Plaintiff also asks the court to vacate and set aside AO 2024-01.

Background

In AO 2024-01, the Commission concluded that a state-registered committee’s proposed canvassing activities did not meet the definition of coordinated communications, coordinated expenditures or public communications. Data acquired from canvassing efforts and shared with a federal candidate or party committee at less than its fair market value, however, would result in an in-kind contribution.

Plaintiff alleges that the Commission’s conclusion in AO 2024-01 unlawfully allows candidates and parties to freely coordinate canvassing expenditures with groups not subject to the Act’s disclosure requirements or contribution limits.

Resources

• Campaign Legal Center v. FEC litigation page