Four Elections for One Seat: Compliance Tips for California’s 2024 US Senate Race

Elections

California will host four elections in 2024 to fill the U.S. Senate seat held by the late Senator Dianne Feinstein and filled by Governor Newsom’s appointment of Senator Laphonza Butler. Sen. Butler has announced that she will not run in the 2024 elections for the seat she currently occupies until November 5, 2024. Consequently, in 2024, four elections will be held to fill the single senate seat.

Given that Sen. Butler’s term ends on election day in 2024, California law requires that a special election be held for a short term of November 6, 2024, through January 2, 2025, the end of the current Congress (special election). In addition, a regular election will be held for a full six-year term starting January 3, 2025, through January 2031 (regular election). The dates of these elections will be held as follows:

Special Election (short term)

Primary: March 5, 2024
General: November 5, 2024

Regular Election (six years)

Primary: March 5, 2024
General: November 5, 2024

Contribution Limits

Contributors to candidates running in each of these California Senate elections may potentially contribute up to four times. Individuals and non-multicandidate political action committees (PACs) may contribute up to $3,300 per election to a federal candidate’s campaign committee. Multicandidate PACs may contribute $5,000 per election. Because the primary and general elections for each of the special and regular elections in 2024 are separate elections for purposes of the contribution limits, individuals and non-multicandidate PACs may contribute up to $13,200 to the campaign of a candidate running in both elections. Multicandidate PACs may contribute up to $20,000 during the 2024 cycle to the campaign committee of a candidate running in both the special and regular elections. As a reminder, California holds a non-partisan blanket primary in which all candidates, regardless of their party affiliation, run on the same ballot. The top two vote-getters in the primary advance to the general election.

Reports

The Federal Election Commission (FEC) recently released updated reporting guidance for California’s Senate elections. Monthly PAC filers should continue to follow the monthly reporting schedule. However, quarterly PAC filers that make contributions or expenditures in connection with the California Senate elections should follow the reporting schedule below:

When disclosing disbursements on an FEC report, PACs should make sure that each is allocated to the correct election (e.g., “special primary,” “special general”). In addition, if contributions are made by check, contributors should make the same notation on the check’s memo line.

The Akin political law team will continue to monitor relevant campaign finance developments. Please do not hesitate to contact us with questions.