The city of Tempe, Arizona increased campaign contribution limits for the 2028 election cycle from individuals to candidates for mayor and City Council from $650 to $690 per contributor. From PACs, the limit increased from $1,300 to $1,370, and from mega PACs, the limit increased from $6,480 to $6,840. The limit on aggregate PAC and mega PAC contributions to a candidate increased from $12,970 to $13,700.

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Hawaii Redefines Corporate Powers to Exclude Election Spending

Hawaii has enacted one of the most significant state-level laws concerning corporate election activity since the U.S. Supreme Court’s landmark decision in Citizens United v. Federal Election Commission. Senate Bill 2471, signed into law by Governor Josh Green, redefines the scope of corporate powers for entities organized or transacting business in Hawaii by explicitly excluding election-related spending. The law is set to take effect on July 1, 2027, though legal challenges are anticipated before that date.

Understanding what the law allows, which entities it covers, and what penalties apply is essential for any organization with a presence in the state.

What Hawaii’s SB 2471 Changes for Corporate Election Activity

At its core, SB 2471 removes election and ballot-issue activity from the scope of powers available to corporations and other artificial legal entities in Hawaii. This means that covered entities will be effectively prevented from paying, contributing, or expending money or anything of value, whether directly or indirectly, to support or oppose a candidate, political committee, or political party.

The law applies beyond candidate elections. Covered entities are also prevented from spending to support or oppose constitutional amendments, county charter amendments, or other ballot questions once those measures have been formally certified or submitted to voters. Additionally, the law removes the authority for covered entities to make donations of any kind, except  charitable donations.

There is an exception for bona fide news stories, commentaries, and editorials. However, even that exception does not apply if the broadcasting, print, online, or digital distribution facility is owned or controlled by a candidate, political committee, or political party.

Which Entities Are Covered Under the New Hawaii Election Spending Law

SB 2471 applies broadly across entity types. The law covers domestic and foreign corporations, professional corporations, credit unions, agricultural cooperative associations, consumer cooperative associations, limited-equity housing cooperatives, limited liability partnerships, limited partnerships, limited liability companies, nonprofit associations, and nonprofit corporations other than committees.

A critical provision of the bill conditions its applicability on ongoing enforcement against foreign entities transacting business in Hawaii. 

Candidate committees, noncandidate committees, and similar committees created under federal law are explicitly granted the power to engage in election and ballot-issue activity.  These carve-outs preserve the ability of political committees to operate within established campaign finance frameworks 

Penalties for Violations of  Hawaii’s Corporate Powers Limits

Any election or ballot-issue activity by a covered entity will be deemed void. Beyond that, the consequences for violations can include suspension of the entity’s authority to operate or transact business in Hawaii, ineligibility for state contracts, designation as a non-compliant entity, revocation of the entity’s operating instrument, involuntary dissolution, and revocation of tax-exempt status where applicable.

Enforcement authority is limited to two state officials: the attorney general and the director of commerce and consumer affairs. This centralized enforcement structure means that private parties and local officials cannot independently pursue violations, Hawaii’s Law in the Context of the Post-Citizens United Landscape

Hawaii is not acting in isolation. The state is one of several jurisdictions that have introduced measures this year addressing the role of corporate powers in elections. These efforts represent an ongoing legislative response to the 2010 Citizens United decision, which held that the federal government’s restriction on independent political expenditures by corporations, associations, and labor unions violated the First Amendment.

While the Citizens United ruling remains the law of the land at the federal level and as applied throughout the states,  Hawaii is approaching the issue in a novel way. SB 2471 received overwhelming bipartisan support in both chambers of the Hawaii legislature, signaling broad political backing for the measure. However, the law is expected to face legal challenges before its effective date of July 1, 2027.

Organizations operating in Hawaii or monitoring state-level campaign finance developments should track the progress of any litigation closely, as court rulings could shape the future  of similar measures in other states.

Steps for Businesses and Organizations to Prepare

Even though the law does not take effect until July 2027, companies and organizations with operations in Hawaii should begin evaluating their existing election and ballot-issue spending activity. Assess whether your entity type is covered under the law. Identify any planned contributions, expenditures, or ballot-measure spending that would need to be curtailed before the effective date.

For organizations operating across multiple states, Hawaii’s new law adds another layer to an already complex patchwork of state-level campaign finance and corporate governance requirements. State and Federal Communications provides compliance consulting services to help government affairs professionals and corporate counsel navigate these evolving obligations.

The New Jersey Election Law Enforcement Commission (ELEC) released their annual report for 2025. Last year’s election had unprecedented campaign spending and a new record for disclosure reports filed. Additionally, 6270 lobbyist reports and 2,419 pay-to-play reports were filed. The report contains policy recommendations for lawmakers, including proposing requiring quarterly and 72/24-hour notice reports for independent expenditure committees. The report can be found at https://www.elec.nj.gov/pdffiles/annual_reports/annual2025.pdf.

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The 2026 legislative session adjourned sine die April 2 after lawmakers passed ethics in procurement and campaign finance bills. Effective July 1, House Bill 889 establishes a vendor debarment process for certain infractions, preventing a bidder from bidding on state projects or services for up to three years. The bill includes a revolving door provision restricting former officials and individuals from working with vendors for one year after leaving public office. Vendors, employees of vendors, or any person working on their behalf must report financial expenditures over $50 related to procurement. House Bill 930 requires all political candidates and political committees to open a separate checking account for the purpose of collecting contributions and paying expenses. Campaign funds must not be commingled with any other account. House Bill 930 was delivered to the governor on April 2, and if signed will be effective July 1.

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Attorney General Drew Wrigley issued an opinion to the North Dakota Office of Secretary of State finding Ethics Commission Advisory Opinion 25-01, regarding candidate campaign expenses, exceeded the commission’s authority to issue advisory opinions. Per Letter Opinion 2025-L-03, the Ethics Commission is limited to issuing opinions based on specified facts or conduct and is not authorized to issue legal conclusions. This opinion follows the earlier 2025-L-01 opinion by Wrigley requiring federal PACs active in state elections to report as a state PAC, in addition to the specified statutory provisions simply requiring federal PACs to file a copy of their FEC reports disclosing the state activity. Despite the statutory exemption from registration for federal PACs, the Elections Division of the Office of Secretary of State has confirmed the only way to file reports in the campaign finance reporting system is by registering with the Office of Secretary of State.

Campaign Finance

Louisiana: “Louisiana Ethics Board Raises Questions About Judges’ Campaign Transparency” by Julie O’Donoghue (Louisiana Illuminator) for Yahoo News

Elections

National: “Democrats Swept Elections Far Beyond the Big Races in Referendum on Trump” by Naftali Bendavid (Washington Post) for MSN

Ethics

California: “Ex-S.F. Human Rights Chief Sheryl Davis Hit with Slew of Ethics Charges” by Michael Barba (San Francisco Chronicle) for MSN

Washington DC: “Jury Finds D.C. ‘Sandwich Guy’ Not Guilty of Assaulting Officer” by Salvador Rizzo (Washington Post) for MSN

Illinois: “Judge Says Immigration Officers’ Use of Force in Chicago ‘Shocks the Conscience’” by Kim Bellware and David Nkamura (Washington Post) for MSN

Oregon: “Judge Rules Trump Administration Failed to Meet Legal Requirements for Deploying Troops to Portland” by Claire Rush and Gene Johnson (Associated Press) for MSN

Oregon: “Oregon Lawmakers Quietly Hire Their Family Members with Taxpayer Money – and Little Oversight” by Carlos Fuentes (Portland Oregonian) for MSN

Tennessee: “Trump Pardons Former Tennessee House Speaker, Top Aide Awaiting Prison” by Natalie Allison (Washington Post) for MSN

A proposed ordinance would limit contributions by individuals to City Council candidates and committees to $2,600 during any election cycle. Currently, contributions are unlimited. The proposed ordinance, introduced at the August 25 City Council meeting, also requires all political committees to file a statement of organization with the clerk of the city no later than 10 days. Political committee is defined in the ordinance to include a group of persons making over $200 in contributions to candidates. If passed the ordinance will be effective immediately.

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Campaign Finance

Illinois: “Illinois Senate President Don Harmon Appeals Potential $9.8 Million Fine for Improperly Accepting Campaign Cash” by Dan Petrella (Chicago Tribune) for Yahoo News

Elections

California: “‘Ghost’ Candidates, Pay-to-Play Accusations: Grossmont school board critics say messages suggest ‘wildly unethical’ campaign efforts” by Kristen Taketa (San Diego Union-Tribune) for MSN

Georgia: “Georgia Appeals Court Upholds Ruling Saying Election Officials Must Certify Results” by Kate Brumback (Associated Press) for MSN

National: “IRS Says Churches Can Endorse Candidates from the Pulpit” by David Fahrenthold (New York Times) for Salt Lake Tribune

Ethics

National: “Roughly 140 EPA Staffers Who Signed ‘Dissent’ Letter Are Put on Leave” by Hannah Natanson and Meryl Kornfield (Washington Post) for MSN

National: “Military Veteran Gets a Life Sentence for Plotting an FBI Attack After His Jan. 6 Arrest” by Michael Kunzelman (Associated Press) for Yahoo News

Kentucky: “For KY Lawmakers, Sexual Harassment Isn’t ‘Ethical Misconduct.’ That Could Change” by Alex Acquisto (Lexington Herald-Leader) for MSN

Missouri: “How Missouri’s Ethical Watchdog Was ‘Quietly Dismantled,’ According to New Report” by Kacen Bayless (Kansas City Star) for MSN

The 83^rd Nevada Legislature adjourned sine die on June 3. During the session, a couple of bills passed relating to the state’s campaign finance law. Assembly Bill 73 requires certain communications with synthetic media to contain a specified disclosure. Assembly Bill 79 revises various aspects of the campaign finance law and establishes a contribution limit of $5,000 for a special election other than a recall election. This contribution limit is applicable regardless of the number of candidates for the office, or whether the special election is held on the same day as a primary election or general election. Both bills have been sent to the governor, and if signed become effective January 1, 2026. This does affect lobbying reporting. The termination and final report is due July 3.

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Campaign contribution limits for individual and PAC donors in 2025 are raised from $6,400 to $6,800 per election.

The State Board of Elections has calculated the new limit based on changes to the consumer price index.

A notice of increase will appear in the North Carolina Register on January 15 and the new limit has already gone into effect as of January 1.

On December 19, the U.S. Government Accountability Office (GAO) published a report on public financing programs in selected states and localities.

The report, required by the 2023 federal appropriations bill, attempts to describe several key characteristics of public campaign financing programs in selected states and localities, such as grant funding, matching funds plans, voucher programs, and qualification and participation requirements.

The GAO also interviewed officials from nine programs to obtain perspectives on candidate participation and reasons for and for not participating in the programs.

Additionally, the report looks at the various legal frameworks of the programs and how observations of campaign financing programs in other states and localities influenced aspects of the respondents’ own program structures.

According to the report, which is relying on a 2024 Brennan Center for Justice report, 14 states and 26 localities offer programs through which candidates running for state or local offices can use public funds to finance their campaigns.

Lobbying and campaign finance thresholds increase January 1, 2025, to reflect changes in the consumer price index.

The thresholds for lobbyist compensation and reimbursement increased from $1,870 to $1,930.

Lobbyist expenditures increased from $940 to $970 per calendar quarter, not including expenditures for an individual’s travel, food, lodging, or membership dues.

If a lobbyist does not intend to exceed $2,220 during a calendar year in expenditures, the lobbyist may file an annual report due on January 10.

Salary reporting thresholds have also increased.

Compensation or reimbursement required to be reported must be reported as an exact amount if the compensation or reimbursement received exceeds $1,112,200.

Regarding campaign finance, a general-purpose and specific-purpose committee may not accept political contributions or expenditures totaling more than $1,080 without filing a campaign treasurer appointment.

Other changes include the threshold at which a contribution from an out-of-state PAC requires certain paperwork increased from $1,080 to $1,110.

The Office of Secretary of State recently updated their list of 2024 election law changes. Changes include mandating all political committees other than candidate committees to file reports electronically as of November 27. Effective January 1, 2025, corporations and individuals are permitted to contribute $15,000 to candidates and $30,000 to PACs or political parties per election cycle. An election cycle begins on the 22nd day after a state general election and goes through 21 days after the next state general election. Previously, contribution limits were per election phase.

The state Democratic Party filed suit against Gov. Kemp in federal court over a 2021 state law allowing candidates to accept unlimited contributions through leadership committees.

Last Thursday, a federal judge ruled in favor of Gov. Kemp.

U.S. District Judge Mark Cohen found the complaint to be speculative in nature and the Democratic Party lacked standing to sue the governor.

Democrats could not point to a specific contribution that had infringed the right of free speech and equal protection rights.

The court noted the attorney general and the Georgia Ethics Commission would be the appropriate parties to sue.