Key Points

  • En banc court affirmed $500 individual contribution limits for city council and $750 for citywide races under Oxnard's Measure B.
  • Court applied deferential Lair v. Motl low evidentiary bar for anti-corruption interest, rejecting dissent's call for heightened standard.
  • Only one of four Randall danger signs was assumed present; independent review found limits closely drawn to anti-corruption interest.
  • Dissent argued limits were targeted at a specific challenger and that city's evidence of gift misconduct did not justify regulating campaign contributions.

The en banc Ninth Circuit on April 22, 2026, affirmed the City of Oxnard's municipal campaign contribution limits, applying a deferential standard of review to the city's anti-corruption justification and finding that the limits were closely drawn to that interest. The decision in Moving Oxnard Forward, Inc. v. Lopez sets the standard for defending local contribution caps in the circuit and marks where the court will and will not find limits too low.

The challenged limits, enacted by 82% of Oxnard voters as part of the Oxnard Government Accountability and Ethics Act (Measure B), restrict individual contributions to city council candidates to $500 per election and to citywide candidates to $750. Political action committee limits are set at $1,000 for council and $1,500 for citywide races. The limits are adjusted for inflation every two years.

The majority opinion, authored by Judge Koh, held that the city established a sufficiently important governmental interest in preventing quid pro quo corruption or its appearance. The court cited four pieces of evidence: a newspaper article alleging corruption, a District Attorney investigation report detailing instances of conduct giving rise to the appearance of corruption, a survey showing 77% of residents wanted a government accountability measure, and the fact that 82% of voters approved Measure B.

The court applied the low evidentiary bar established in Lair v. Motl, 873 F.3d 1170 (9th Cir. 2017), noting that 'the City offered more than enough evidence to demonstrate its interest in preventing actual or perceived quid pro quo corruption.' The majority rejected the dissent's argument that the city needed evidence of actual quid pro quo corruption tied specifically to campaign contributions, rather than gifts or travel.

Turning to the second step of the Buckley-Randall framework, the court analyzed the four 'danger signs' that contribution limits may be unconstitutionally low. The majority found that the first three danger signs were not present: the limits are per candidate per election (not per cycle); higher limits apply to PACs and no limits apply to political parties; and the limits are comparable to those of other California cities of similar size.

The court assumed without deciding that the fourth danger sign—whether the limit is below previously upheld limits—was present, because the Supreme Court has only addressed state and federal limits, not city limits. That assumption triggered an independent examination of the record under the five considerations set forth in Randall v. Sorrell, 548 U.S. 230 (2006).

On the five considerations, the court found that four favored Measure B: the limits do not significantly restrict challengers' ability to raise funds; political party contributions are not limited; volunteer services are properly exempted; and the limits are indexed for inflation. Because the first four factors weighed in the city's favor, the court held that a special justification was unnecessary.

The majority pointed to evidence that in the 2018 election, only 6.3% of donors made contributions that would have exceeded Measure B's limits, and only two candidates raised a majority of their funds from such contributions. The court also noted that plaintiff Aaron Starr was elected to the city council in 2024 while Measure B was in effect. The majority wrote: 'Starr’s testimony thus primarily reflects his personal belief as to the value of raising small contributions and the effect of Measure B on his personal fundraising strategy, not that Measure B “harm[s] the electoral process by preventing challengers from mounting effective campaigns against incumbent officeholders, thereby reducing democratic accountability.”'

The court also rejected the challenge to Measure B's aggregate contribution limits, holding that the plain text applies only to contributions made to a candidate, not to ballot measure committees. The majority reasoned that the aggregate limits constitute a permissible base limit under McCutcheon v. FEC and do not discriminate between candidates based on their sponsorship of ballot measures.

The dissenting opinion argued that the low Lair/Eddleman standard is inconsistent with Supreme Court precedent and would require evidence of actual quid pro quo corruption. The dissent also argued that Measure B presents sufficient danger signs—including evidence that the limits were targeted at Starr—to warrant independent scrutiny. The dissent stated: 'I would hold that the City has failed to carry its threshold burden to show that these limits “further the important state interest of preventing quid pro quo corruption or its appearance.”'

For the foregoing reasons, the en banc court affirmed the district court's grant of summary judgment in favor of the city and denied the plaintiff's motion for summary judgment.