Court grants plaintiff’s motion for summary judgment in Campaign Legal Center v. FEC (24-02585)

On June 26, 2025, the United States District Court for the District of Columbia (the Court) granted summary judgment to Campaign Legal Center (Plaintiff). Plaintiff had challenged the FEC's dismissal of an administrative complaint as arbitrary, capricious and contrary to law.

Background

On September 9, 2024, Plaintiff filed suit, challenging the FEC's dismissal of an administrative complaint it filed against Last Best Place PAC (LBP PAC) for alleged violations of disclosure and reporting requirements under the Federal Election Campaign Act (the Act). The complaint alleged that LBP PAC treated disbursements for advertising as operating expenditures, despite one or more of the ads expressly advocating the election or defeat of a clearly identified federal candidate. The Commission dismissed the complaint and the Commissioners who voted to dismiss the complaint issued a Statement of Reasons to that effect.

Analysis

The Plaintiff claims that the FEC's dismissal was contrary to law, and although the Court found that the Commission did not rest its decision on an impermissible interpretation of the Act, it did find that the Commission acted arbitrarily and capriciously because it did not adequately explain its dismissal. The Court stated that an agency must provide an explanation enabling the court to evaluate the agency's rationale at the time of the decision. The Statement of Reasons did not allow it to evaluate the agency's rationale for dismissal. Because of this, the Court granted the Plaintiff's motion for summary judgment, denied the Commission's cross-motion for summary judgment and remanded the matter to the FEC with instructions to conform to the Court's order within 30 days.

Resources