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The costs associated with mounting a full-fledged political campaign for federal, state, and local offices have increased tremendously over the past few decades.' As costs have skyrocketed, so has the need for campaign contributions to cover them. For most candidates, the preferable and most efficient way to raise campaign funds is to solicit large contributions from wealthy donors.2 The alternative would be to spend greater time and effort soliciting thousands of small contributions from a larger pool of donors.3 While the first approach is attractive, its main criticism has been the conflict of loyalties it can create for the candidate. While she is elected by the majority in her district and therefore is at least nominally answerable to her constituents, a cynical view dictates that she owes her victory to those few who funded her campaign.4 Once she is elected, this cynical view continues that

Alaska Gives Ninth Circuit the Cold Shoulder: Conflicts in Campaign Finance Jurisprudence