December 22, 2025

Latest Developments:

• Supreme Court Considers Removing Political Party Spending Limits The Court heard arguments in a case that could shift power from Super PACs back to political parties if it lifts limits on parties’ spending in coordination with candidates. Republican proponents argue that limits hinder parties’ free-speech rights, while Democratic opponents argue limits are necessary to avoid quid pro quo corruption and prevent wealthy donors from doing an end-run around individual contribution limits. NYT – Court Grapples with Campaign Finance Limits and Washington Post – Court Weighs with Loosening Limits. For a discussion about Oral Argument co-hosted by the ABA Standing Committee on Election Law, see: https://www.youtube.com/watch?v=q5bORd147AU

• Benchmarking on Political Disclosure by Corporations The 2025 CPA-Zicklin Index of Corporate Political Disclosure and Accountability is out, measuring “how transparently companies report and oversee their election-related spending” using shareholder or corporate money, tracking S&P 500 and Russell 1000 companies. The report found “a continued trend towards more disclosure. More than 22% (112) of the S&P 500 scored 90% or up on the Index’s accountability measures, up roughly 10% from just one year ago, and more than four times the level in 2015.” See the report here: 2025-CPA-Zicklin-Index.pdf

• Corporations Will Be on the Ballot in 2026 “The rise of anti-corporate feelings in both political parties has created the most perilous political environment for companies and trade associations in Washington in a half century,” according to a column by Brody Mullins. See Noosphere, lobbying column

• Trump Transition Donors Listed, But Contributions Not Disclosed One year later, the administration released a list of 46 donors – including multiple billionaires and political appointees – who gave more than $14 million to finance the Trump transition, but did not specify the amounts each donated, shielding donors from full transparency about potential conflicts of interest or pay-for-play arrangements. Transition donors finally disclosed – New York Times

Events and Reminders:

• The New York State Commission on Ethics and Lobbying in Government has created a new 30-minute video, Understanding Lobbying – Source of Funding Training, which includes step-by-step instructions on how to determine if a filer is required to disclose sources of funding and how to do so. The video supplements other online resources, found here: Resources – Source of Funding and Reportable Business Information

• The Washington State Public Disclosure Commission issued a reminder regarding the legislative session freeze that took effect December 13 and runs through the day of the 2026 legislative session’s final adjournment. For more information, see Legislative Session Freeze | Washington State Public Disclosure Commission (PDC)

In Case You Missed It:

• Campaign Spending for Wisconsin Supreme Court Seats Scrutinized Wisconsin Watch analyzed campaign finance and other laws to help explain how Wisconsin Supreme Court campaign spending “exploded” between 2007 and 2025 to “a national record of $114.2 million — almost 20 times the cost of that first big-money election 18 years earlier.” Unlimited donations, weak recusal rules led to record Wisconsin Supreme Court spending

• Georgia Case on Gifts of Food and Water to Voters Remanded The Eleventh Circuit remanded a case considering Georgia’s ban on handing out food and water to voters standing in line, ordering a lower court to update its analysis of voting rights advocates’ First Amendment claims by considering Moody v. NetChoice. 11th Circ. Orders Do-Over On Ga. Voting Line Gift Ban – Law360

• NY Governor Refunding Donations from Appointees After a story by Gothamist, Gov. Kathy Hochul’s campaign says that she will refund at least $72,500 in political donations from people who occupy appointed positions and are prohibited from donating to a gubernatorial campaign. NY Gov. Hochul accepted — and is now refunding — thousands in donations from appointees – Gothamist

• Stephen Miller’s Stock Sale Raises Ethics Questions Ethics experts are scrutinizing the Trump official’s sale of shares worth $50,000 to $100,000 in the mining company MP Materials, which occurred one month after the administration announced a deal with the company in which the government will purchase shares in the company and commit to buying its products. Stephen Miller’s Stock Sale Raises Questions, Ethics Experts Say

• LA Ethics Alleges DWP Employee Used Staff for Errands, Snoop Dogg Tickets The Los Angeles City Ethics Commission has opened a case alleging that a high-ranking employee at the Department of Water and Power made staffers run personal errands for her, including purchasing tickets to a Snoop Dogg concert. The employee denies the claims. DWP employee made assistants run personal errands, ethics enforcer says

Editor’s note

This is the final edition of Essential Ethics for 2025, which will resume in January 2026. Happy Holidays!