District court dismisses McDonald v. FEC (25-153)

On July 9, 2025, the United States District Court for the Northern District of Texas Fort Worth Division (the court) granted the Commission's motion to dismiss for lack of subject matter jurisdiction.

Background

On February 18, 2025, Tony McDonald (plaintiff) filed suit claiming that the disclosure of contributor names and addresses of conduitcontributions not exceeding $200 violates the First Amendment. As relief, plaintiff sought a permanent injunction barring the FEC from requiring this information from fundraising platforms when reporting conduit contributions and asked the court to order the FEC to remove plaintiff's past small-amount conduit contributions from the public record. On April 22, 2025, the FEC filed a motion to dismiss.

Analysis

The court noted that the threshold issue presented by the FEC's motion is whether plaintiff can demonstrate an injury sufficient to show standing, thereby establishing subject matter jurisdiction. Proof of standing requires three elements. Plaintiff must show (1) he suffered an injury in fact; (2) a causal connection between the injury and the conduct complained of; and (3) a likelihood that the injury will be redressed by a favorable decision.

The court found that the plaintiff failed to demonstrate an injury in fact. Plaintiff did not allege that he faced the threat of an enforcement action or that he was forced to explain or justify contributions. Rather, the plaintiff argued that he suffered a "First Amendment" injury when his donor information was disclosed. The court held that the disclosure of donor information is not a "constitutional injury in and of itself."

The court concluded that plaintiff "has shown no reason why the Court should abandon an injury-in-fact inquiry solely because his claim involves the disclosure of campaign contributions." Accordingly, the court granted the Commission's Motion to Dismiss for Lack of Jurisdiction and dismissed the case without prejudice.

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