Alabama Democratic Conference v. Strange:

Alabama’s Fair Campaign Practices Act (“FCPA”) prohibits a political action committee (“PAC”) from making contributions, expenditures, or transfers of funds to another PAC, except that a PAC that is not a “principal campaign committee” may make contributions, expenditures, or transfers of funds to a principal campaign committee. ALA. CODE § 17-5-15(b). This law was enacted in response to concerns that donors were concealing their contributions to candidates by “laundering” those contributions through multiple PACs before the donation finally arrived with a candidate. The broad language of the statute prohibits all contributions, expenditures, and transfers of funds between PACs, except as noted above, including those from one PAC to a second PAC where the money is to be used solely for “independent expenditures.” The Alabama Democratic Conference (“the ADC”) asserts the prohibition on its ability to receive contributions to be used solely for independent expenditures violates the PAC’s First Amendment rights. At the outset, the court notes that the ADC does not challenge ALA. CODE § 17-5-15(b) on its face, but rather brings an as applied challenge. (Doc. 1 at ¶¶ 29-43)….

In this case, the court finds that the ban on contributions, expenditures, and transfers of funds to the ADC from other PACs is closely drawn to further the State’s anti-corruption interest. In light of lack of evidence of organizational separation or other safeguards to prevent contributions that are nominally for independent expenditures ending up in the Candidate Account, the court cannot say that a more narrowly tailored solution, such a limit on the amount another PAC could contribute to ADC, would adequately protect the State’s interest. Given the lack of safeguards, even a small donation could end up in the wrong account. Further, the impact of the PAC-to-PAC transfer ban on the ADC’s associational rights is minimal. The ADC is still able to receive unlimited contributions from individuals; it can still make unlimited contributions to candidates; and it can make unlimited independent expenditures. Because ALA. CODE § 17-5-15(b) is closely drawn to serve a sufficiently important state interest, the ADC’s as applied constitutional challenge must fail. See Catholic Leadership oal. of Texas, 764 F.3d at 445 (“Likewise, Texas’s complete ban on Plaintiffs’ proposed contribution is closely drawn to its anticircumvention interest insofar as Plaintiffs have failed to provide any clear safeguard that sufficiently assures that no part of the corporate contribution will end up being transferred to a candidate.”).