The Taft Court ruled in Newberry v. United States (1921) that Congress did not have the constitutional authority to regulate spending in congressional primary elections. The Court’s decision invalidated the convictions of Truman Newberry and sixteen others under the federal Corrupt Practices Act, which limited the contributions and expenditures of congressional candidates for House and Senate seats.

The government argued that the Corrupt Practices Act was justified by Section 4, Article I, of the Constitution, which provides: “The times, places and manner of holding elections for Senators and Representatives shall be prescribed in each state by the Legislature thereof.” The Court concluded that this congressional grant of power to control elections did not apply to party primaries or conventions. The Court reasoned that congressional control over primaries “would interfere with purely domestic affairs of the state and infringe upon liberties reserved to the people.” The Court’s decision caused Congress to pass a new law regulating elections called the Federal Corrupt Practices Act of 1925.