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{{Short description|2010 U.S. Supreme Court decision}}
{{redirect|Citizens United|the political organization|Citizens United (organization)|other uses|Citizens United (disambiguation)}}
{{Use mdy dates|date=October 2018}}
{{Infobox SCOTUS case
| Litigants = Citizens United v. Federal Election Commission
| ArgueDate = March 24
| ArgueYear = 2009
| ReargueDate = September 9
| ReargueYear = 2009
| DecideDate = January 21
| DecideYear = 2010
| FullName = [[Citizens United (organization)|Citizens United]], Appellant v. [[Federal Election Commission]]
| USVol = 558
| USPage = 310
| ParallelCitations = 130 S. Ct. 876; 175 [[L. Ed. 2d]] 753; 2010 [[U.S. LEXIS]] 766
| Docket = 08-205
| OralArgument = https://www.oyez.org/cases/2008/08-205
| OralReargument =
| OpinionAnnouncement =
| Prior = ''Motion for preliminary injunction denied'', 530 [[F. Supp. 2d]] 274 ([[D.D.C.]] 2008);<ref name="Cornell"/> ''probable jurisdiction noted'', 555 U.S. 1028 (2008).
| Subsequent =
| Holding = The provisions of the [[Bipartisan Campaign Reform Act of 2002]] restricting unions, corporations, and profitable organizations from independent political spending and prohibiting the broadcasting of political media funded by them within sixty days of general elections or thirty days of primary elections violate the [[freedom of speech]] that is protected by the [[First Amendment to the United States Constitution|First Amendment]] to the [[Constitution of the United States]]. United States District Court for the District of Columbia reversed.
| Majority = Kennedy
| JoinMajority = Roberts, Scalia, Alito; Thomas (all but Part IV); Stevens, Ginsburg, Breyer, Sotomayor (Part IV)
| Concurrence = Roberts
| JoinConcurrence = Alito
| Concurrence2 = Scalia
| JoinConcurrence2 = Alito; Thomas (in part)
| Concurrence/Dissent = Stevens
| JoinConcurrence/Dissent = Ginsburg, Breyer, Sotomayor
| Concurrence/Dissent2 = Thomas
| LawsApplied = [[First Amendment to the United States Constitution|U.S. Const. amend. I]], [[Bipartisan Campaign Reform Act of 2002]]
| Overturned previous case = {{plainlist|
*''[[Austin v. Michigan Chamber of Commerce]]'' (1990)
*''[[McConnell v. FEC]]'' (2003) (in part)}}
}}

'''''Citizens United v. Federal Election Commission''''', 558 U.S. 310 (2010), is a [[List of landmark court decisions in the United States|landmark decision]] of the [[Supreme Court of the United States]] regarding [[Campaign finance in the United States|campaign finance]] laws and free speech under the [[First Amendment to the United States Constitution|First Amendment]] to the [[Constitution of the United States|U.S. Constitution]]. The court held 5–4 that the freedom of speech clause of the First Amendment prohibits the government from restricting [[independent expenditure]]s for political campaigns by corporations, nonprofit organizations, labor unions, and other associations.

The majority held that the prohibition of all independent expenditures by corporations and unions in the [[Bipartisan Campaign Reform Act]] violated the First Amendment.<ref name=":4"> ''Citizens United v. Federal Election Com'n'', [https://scholar.google.com/scholar_case?case=14627663605033036164&q=558+U.S.+310&hl=en&as_sdt=6,39 558 U.S. 310] (S. Ct., 2010).</ref> The ruling barred restrictions on corporations, unions, and nonprofit organizations from independent expenditures, allowing groups to independently support political candidates with financial resources. In a dissenting opinion, Justice [[John Paul Stevens]] argued that the court's ruling represented "a rejection of the common sense of the American people, who have recognized a need to prevent corporations from undermining self government".<ref>{{Cite web|title=The Supreme Court Deals Another Blow to Representative Democracy – Capitol Perspective|url=https://www.nypirg.org/capitolperspective/the-supreme-court-deals-another-blow-to-representative-democracy/|access-date=2020-12-01|language=en-US}}</ref>

The decision remains highly controversial, generating much public discussion and receiving strong support or opposition from various politicians, commentators, and advocacy groups. Senator [[Mitch McConnell]] commended the decision, arguing that it represented "an important step in the direction of restoring the First Amendment rights".<ref>{{Cite web|author=Politico Staff|title=Pols weigh in on Citizens United decision|url=https://www.politico.com/story/2010/01/pols-weigh-in-on-citizens-united-decision-031798|access-date=2020-12-01|website=POLITICO|date=January 21, 2010 |language=en}}</ref> By contrast, then-president President [[Barack Obama]] stated that the decision "gives the special interests and their lobbyists even more power in Washington".<ref>{{Cite web|last=Smith|first=Ben|title=Obama on Citizens United: 'Stampede of special interest money'|url=https://www.politico.com/blogs/ben-smith/2010/01/obama-on-citizens-united-stampede-of-special-interest-money-024406|access-date=2020-12-01|website=POLITICO|date=January 21, 2010 |language=en}}</ref>

== Background ==
[[Citizens United (organization)|Citizens United]] had previously used the 2002 [[Bipartisan Campaign Reform Act]], commonly known as the McCain–Feingold Act or BCRA, which prohibited "electioneering communications" by incorporated entities.<ref name="LiptakJan2010">{{Cite news |last=Liptak |first=Adam |date=January 21, 2010 |title=Justices, 5–4, Reject Corporate Spending Limit |url=https://www.nytimes.com/2010/01/22/us/politics/22scotus.html |work=[[The New York Times]]}}</ref> During the [[2004 United States presidential election|2004 presidential campaign]], the organization filed a complaint with the [[Federal Election Commission]] (FEC) charging that advertisements for [[Michael Moore]]'s film ''[[Fahrenheit 9/11]]'', a [[docudrama]] critical of the [[George W. Bush|Bush administration's]] response to the [[September 11 attacks|terrorist attacks on September 11, 2001]], constituted political advertising and thus could not be aired within the 30 days before a primary election or 60 days before a general election. The FEC dismissed the complaint after finding no evidence that advertisements featuring a candidate within the proscribed time limits had actually been made.<ref>[http://www.fec.gov/press/press2004/20040806mur.html FEC finding] August 6, 2004.</ref> In response, Citizens United produced the documentary ''[[Celsius 41.11]]'', which is highly critical of both ''Fahrenheit 9/11 ''and 2004 Democratic presidential nominee [[John Kerry]]. The FEC, however, held that showing ''Celsius 41.11'' and advertisements for it would violate the [[Federal Election Campaign Act]], because Citizens United was not a bona fide commercial film maker.<ref>[https://www.fec.gov/files/legal/aos/59174.pdf "Advisory Opinion 2004-30"] Federal Election Commission, September 10, 2004.</ref>

In the wake of these decisions, Citizens United sought to establish itself as a bona fide commercial filmmaker before the 2008 elections, producing several documentary films. During the [[2008 Presidential election in the US|2008 political primary season]], it sought to run three television advertisements to promote its political documentary ''[[Hillary: The Movie]]'', a film that was critical of [[Hillary Clinton]], and to air the movie on [[DirecTV]].<ref name="Barnes">{{Cite news|last=Barnes|first=Robert |title='Hillary: The Movie' to Get Supreme Court Screening |url=https://www.washingtonpost.com/wp-dyn/content/article/2009/03/14/AR2009031401603_pf.html |date=March 15, 2009 |newspaper=[[The Washington Post]] |access-date=March 22, 2009}}</ref> The FEC found this plan to be in violation of the BCRA, including Section 203 which defined an "electioneering communication" as a broadcast, cable, or satellite communication that mentioned a candidate within 60 days of a general election or 30 days of a primary, and prohibited such expenditures by corporations and labor unions. The FEC prohibited the film from being broadcast, and Citizens United challenged this determination in court.<ref name="Cornell">{{cite web |title=Summary Citizens United v. Federal Election Commission (Docket No. 08-205) |url=http://topics.law.cornell.edu/supct/cert/08-205 |url-status=live |archive-url=https://web.archive.org/web/20170124175326/https://www.law.cornell.edu/supct/cert/08-205 |archive-date=January 24, 2017 |access-date=January 24, 2017 |publisher=[[Cornell Law School|Cornell University School of Law]]}}</ref>

== District Court proceedings ==
In December 2007, Citizens United filed a complaint in [[United States District Court for the District of Columbia|U.S. District Court for the District of Columbia]] challenging the constitutionality of several statutory provisions governing "electioneering communications".<ref name=FECL>{{cite web|url=http://www.fec.gov/law/litigation_CCA_C.shtml#search=hillary%20the%20movie |title=FEC Litigation |publisher=Federal Election Commission}}</ref> It asked the court to declare that the prohibition on corporate and union funding were [[Facial challenge|facially unconstitutional]], and also as applied to ''Hillary: The Movie'' and to the 30-second advertisement for the movie, and to [[Injunction|enjoin]] the Federal Election Commission from enforcing its regulations. Citizens United also argued that the commission's disclosure and disclaimer requirements were unconstitutional as applied to the movie pursuant to the Supreme Court decision in ''[[Federal Election Commission v. Wisconsin Right to Life, Inc.]]'' and sought to enjoin those requirements as well.<ref>{{Cite book|last=Court|first=United States Supreme|url=https://books.google.com/books?id=OW6bAMgsHagC|title=So Much for Democracy: Citizens United V. Federal Election Commission|date=October 2009|publisher=Nimble Books LLC|isbn=978-1-60888-021-8|language=en}}</ref><ref>{{Cite book|last=Steele|first=Kris|url=https://books.google.com/books?id=hqcwnQAACAAJ|title=Oklahoma Ethics Laws in Response to Citizens United V. Federal Election Commission|date=2011|publisher=Rules Committee, Oklahoma House of Representatives|language=en}}</ref>

In accordance with Section 403 of the BCRA, a three-judge panel was convened to hear the case. On January 15, 2008, the court denied the Citizens United motion for a preliminary injunction, finding that the suit had little chance of success because the movie had no reasonable interpretation other than as an appeal to vote against Hillary Clinton. Therefore the film was an item of express advocacy, not entitled to exemption from the ban on corporate funding of electioneering communications.<ref name="Ref_2008">{{cite web|title=Memorandum Opinion |work=Citizens United v. Federal Election Commission |publisher=District Court for the District of Columbia |date=January 15, 2008 |url=https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2007cv2240-39 |format=PDF |access-date=February 1, 2010}}</ref> The court held that the Supreme Court in ''[[McConnell v. FEC]]'' (2003) had found the disclosure requirements of the BCRA constitutional, while the ''Wisconsin Right to Life'' precedent was not relevant because it only addressed speech that was not considered express advocacy.<ref name=":3">{{Cite book|last1=Sullivan|first1=Kristin|url=https://books.google.com/books?id=FuNTAQAACAAJ|title=Summary of Citizens United V. Federal Election Commission|last2=Adams|first2=Terrance P.|date=2010|publisher=Connecticut General Assembly, Office of Legislative Research|language=en}}</ref> 

On July 18, 2008, the District Court ruled that Section 203 of the BCRA prohibited Citizens United from paying to have the film shown on television within 30 days of the [[Democratic Party (United States) presidential primaries, 2008|2008 Democratic primaries]]; however, Citizens United would be able to broadcast the advertisements for the film as they fell in the "safe harbor of the FEC's prohibition regulations".<ref name="Cornell" /><ref name="Ref_2008" /><ref name="Liptak2009">{{Cite news |last=Liptak |first=Adam |date=August 29, 2009 |title=Supreme Court to Revisit 'Hillary' Documentary |url=https://www.nytimes.com/2009/08/30/us/30scotus.html |url-status=live |archive-url=https://archive.today/20130104071103/http://www.nytimes.com/2009/08/30/us/30scotus.html?_r=0 |archive-date=January 4, 2013 |access-date=January 24, 2017 |work=The New York Times}}</ref><ref name=":3" />

In accordance with the special rules in BCRA, Citizens United appealed the District Court decision directly to the [[Supreme Court of the United States|U.S. Supreme Court]].<ref name="Holland">{{cite news|last=Holland|first=Jesse J.|title="Hillary: The Movie" next on Supreme Court docket|url=http://seattletimes.nwsource.com/html/politics/2008901901_nationweek22.html|work=Seattle Post-Intelligencer|agency=Associated Press|date=March 22, 2009|access-date=May 10, 2011}}</ref><ref name="Ref_2008a">{{cite web|title=Docket for 08-205 |publisher=[[U.S. Supreme Court]] |url={{SCOTUS URL Docket|08-205}} |date=August 18, 2008}}</ref>

==Arguments before the Supreme Court==
Arguments before the Supreme Court began on March 24, 2009.<ref name="Barnes" /><ref name="Ross">{{Cite news |last=Ross |first=Lee |title=March 24: Hillary Clinton Film Challenged |url=https://www.foxnews.com/story/march-24-hillary-clinton-film-challenged |date=March 18, 2009 |publisher=[[Fox News]] |access-date=March 22, 2009 |url-status=live |archive-url=https://web.archive.org/web/20090325015643/http://www.foxnews.com/story/0,2933,509712,00.html?sPage=fnc%2Fus%2Fsupremecourt |archive-date=March 25, 2009 }}</ref> During the original [[Oral argument in the United States|oral argument]], Deputy Solicitor General Malcolm L. Stewart (representing the FEC) argued that under ''[[Austin v. Michigan Chamber of Commerce]]'' in 1990, the government would have the power to ban books if those books contained even one sentence expressly advocating the election or defeat of a candidate and were published or distributed by a corporation or labor union.<ref name="Liptak2009a">{{Cite news| last=Liptak|first=Adam |title=Justices Seem Skeptical of Scope of Campaign Law |work= The New York Times |date=March 25, 2009 |page= A16|url=https://www.nytimes.com/2009/03/25/washington/25scotus.html}}</ref> Stewart further argued that under ''Austin'' the government could ban the digital distribution of political books over the [[Amazon Kindle]] or prevent a union from hiring an author to write a political book.<ref name="Smith">{{Cite news| last=Smith|first=Bradley| title=The Myth of Campaign Finance Reform |url=http://www.nationalaffairs.com/publications/detail/the-myth-of-campaign-finance-reform}}</ref>

Justice Kennedy later explained how "all of us are concerned with money in politics". However, he was shocked that "the government of the United States ... argued before the Supreme Court ... that if there was an upcoming political campaign ... and a book was being published ... and it was critical of a candidate, that [the government] could stop publication".<ref> {{cite AV media | people = Bloomberg Television | title = Justice Kennedy Says 'There's a Problem of Money in Politics' | url = https://www.youtube.com/watch?v=Z9OYc2JXocY | format = Video | language = English | date = 2017-11-28 | publisher = Bloomberg Television | access-date = 2024-05-09 }}</ref>

According to a 2012 retrospective article in ''[[The New Yorker]]'' by [[Jeffrey Toobin]], the court planned to rule on the narrow question that had originally been presented: Can Citizens United show the film? At the conference among the justices after oral argument, the vote was 5–4 in favor of Citizens United being allowed to show the film. The justices voted the same as they had in ''[[Federal Election Commission v. Wisconsin Right to Life, Inc.]]'', a similar 2007 case.<ref name="Toobin 2012 New Yorker article">{{cite news|last=Toobin|first=Jeffrey|author-link=Jeffrey Toobin|title=Annals of Law: Money Unlimited|url=https://www.newyorker.com/reporting/2012/05/21/120521fa_fact_toobin|newspaper=[[The New Yorker]]|date=May 21, 2012|access-date=May 20, 2012}}</ref>

Chief Justice [[John Roberts]] wrote the initial opinion of the court, holding that BCRA allowed the showing of the film. A draft [[concurring opinion]] by Justice [[Anthony Kennedy]] argued that the court should have gone much further. The other justices in the majority agreed with Kennedy's reasoning, and convinced Roberts to reassign the writing and allow Kennedy's concurrence to become the majority opinion.<ref name="Toobin 2012 New Yorker article" /> On the minority side, Justice [[John Paul Stevens]] assigned the [[dissenting opinion]] to [[David Souter]], with Souter completing the task shortly before retiring from the court. The final draft of the dissent went beyond critiquing the majority. Toobin described it as airing "some of the Court's dirty laundry", as Souter accused Roberts of having manipulated court procedures to reach his desired result—an expansive decision that changed decades of election law and ruled on issues neither party to the litigation had presented. According to Toobin, Roberts agreed to withdraw the opinion and schedule the case for re-argument. When he did, the questions presented to the parties were, however, more expansive, touching on the issues Kennedy's opinion had identified.<ref name="Toobin 2012 New Yorker article" /> 

The court issued an order directing the parties to re-argue the case on September 9, 2009 with a discussion of whether it might be necessary to overrule ''Austin'' and/or ''[[McConnell v. Federal Election Commission|McConnell v. FEC]]'' to decide the case.<ref name="Barnes2009">{{Cite news|last=Barnes|first=Robert |title=Justices to Review Campaign Finance Law Constraints |url= https://www.washingtonpost.com/wp-dyn/content/article/2009/06/29/AR2009062903997_pf.html |date=June 30, 2009 |newspaper=The Washington Post}}</ref> The re-argument was one of the first attended by Justice [[Sonia Sotomayor]], who had replaced Souter in the interim. It was also the first case argued by then-Solicitor General and future Supreme Court Justice [[Elena Kagan]]. Former Solicitor General [[Theodore Olson|Ted Olson]] and First Amendment lawyer [[Floyd Abrams]] argued for Citizens United, and another former Solicitor General [[Seth Waxman]] defended the statute on behalf of various supporters.<ref name="Ref_a">{{cite news|title=Hillary: The Oral Argument |url= http://voices.washingtonpost.com/postpartisan/2009/09/hillary_the_oral_argument.html |archive-url= https://archive.today/20120715162910/http://voices.washingtonpost.com/postpartisan/2009/09/hillary_the_oral_argument.html |url-status= dead |archive-date= July 15, 2012 |newspaper= The Washington Post}}</ref> Legal scholar [[Erwin Chemerinsky]] called it "one of the most important First Amendment cases in years".<ref name="Liptak2009b">{{cite news|last=Liptak|first=Adam |title=Sotomayor Faces Heavy Workload of Complex Cases |url= https://www.nytimes.com/2009/08/07/us/politics/07scotus.html |work= The New York Times |date=August 6, 2009}}</ref>

== Opinion of the court ==
On January 21, 2010, the court issued a 5–4 decision in favor of Citizens United that struck down the BCRA restrictions on independent political expenditures by corporations as violations of the First Amendment, in a reversal of the District Court opinion.<ref name="LiptakJan2010" /><ref>{{cite book | first=Erwin | last=Chemerinsky | title=Constitutional Law: Principles and Policies | edition= 6th | location=New York | publisher=Wolters Kluwer | year=2019 | isbn=978-1-4548-9574-9 |at=§&nbsp;11.3.6.3, p. 1184 }}</ref>

===Majority opinion===
[[Image:Anthony Kennedy official SCOTUS portrait crop.jpg|175px|thumb|Justice Kennedy, the author of the court's opinion]]

The majority opinion was written by the moderate Justice [[Anthony Kennedy]], who chose to align with the more conservative justices. The court held that BCRA Section 203's prohibition of all independent political expenditures by corporations and unions violated the First Amendment's protection of free speech.<ref name="autogenerated2">[https://www.supremecourt.gov/opinions/09pdf/08-205.pdf Syllabus : Citizens United v. Federal Election Commission], Supreme Court of the United States.</ref> As Kennedy wrote, "If the First Amendment has any force, it prohibits Congress from fining or jailing citizens, or associations of citizens, for simply engaging in political speech."<ref name="TNY20120521">{{cite news|last=Toobin|first=Jeffrey|title=Money Unlimited: How Chief Justice John Roberts orchestrated the Citizens United decision|url=https://www.newyorker.com/reporting/2012/05/21/120521fa_fact_toobin?currentPage=all|access-date=October 16, 2012|newspaper=[[The New Yorker]]|date=May 21, 2012}}</ref> Kennedy also noted that because the First Amendment does not distinguish between media and other corporations, the BCRA restrictions improperly allowed Congress to suppress political speech in newspapers, books, television, and blogs.<ref name="LiptakJan2010" /> Consequently, "There is no such thing as too much speech."<ref name="autogenerated2" />

The court overturned the 1990 precedent ''[[Austin v. Michigan Chamber of Commerce]]'', which had held that a state law that prohibited corporations from using money to support or oppose candidates in elections did not violate the Constitution. The majority criticized ''Austin's'' reasoning that the "distorting effect" of large corporate expenditures constituted a risk of [[corruption]] or the [[appearance of corruption]]. Rather, the majority argued that the government had no place in determining whether large expenditures distorted an audience's perceptions, and that the type of "corruption" that might justify government controls on spending for speech had to relate to some form of "[[quid pro quo]]" transaction in which politicians favored corporations from whom they received donations.<ref name="autogenerated2" /> The court also overruled a portion of the 2003 precedent ''[[McConnell v. FEC]]'' that upheld the BCRA restriction of corporate spending on electioneering communications.<ref name=":4" />

The majority also held that the [[Freedom of the press in the United States|free press]] clause of the First Amendment protects ''associations'' of individuals in addition to individual speakers, and further that the First Amendment does not allow prohibitions of speech based on the identity of the speaker. Corporations, as associations of individuals, therefore have free speech rights under the First Amendment. Because spending money is essential to disseminating speech, as established in the 1976 precedent ''[[Buckley v. Valeo]]'', limiting a corporation's ability to spend money is unconstitutional by limiting the ability of its members to associate effectively and to speak on political issues.<ref name=":4" /> The court's opinion relied heavily on ''Buckley'' and ''[[First National Bank of Boston v. Bellotti]]'', in which it struck down a broad prohibition of independent expenditures by corporations in ballot initiatives and referendums. The majority argued that the First Amendment purposefully keeps the government from "rationing" speech and interfering in the [[marketplace of ideas]], and it is not up to legislatures or courts to create a sense of "fairness" by restricting speech.<ref name="autogenerated2" /> 

On the other hand, the court found that BCRA Sections 201 and 311, which require disclosure of information of the funders of such speech, were valid as applied to the movie advertisements and to the movie itself.<ref name="autogenerated2" /> The majority ruled for the disclosure of the sources of campaign contributions, saying that:{{blockquote|...prompt disclosure of expenditures can provide shareholders and citizens with the information needed to hold corporations and elected officials accountable for their positions and supporters. Shareholders can determine whether their corporation's political speech advances the corporation's interest in making profits, and citizens can see whether elected officials are "in the pocket" of so-called moneyed interests&nbsp;... This transparency enables the electorate to make informed decisions and give proper weight to different speakers and messages.<ref>{{cite news |magazine=[[The Nation]] |title=The Republican Governors Thank You for Your Donation |first=Jamie |last=Raskin |author-link=Jamie Raskin |date=January 14, 2015 |access-date=August 28, 2015 |url=http://www.thenation.com/article/republican-governors-thank-you-your-donation/}}</ref><ref>{{cite news |publisher=[[Politico]] |title=Who is paying for political ads? |first1=Newton |last1=Minow |author-link1=Newton Minow |first2=Henry |last2=Geller |date=December 11, 2011 |access-date=August 28, 2015 |url=http://www.politico.com/story/2011/12/who-is-payingfor-political-ads-070263}}</ref>}}

=== Concurring opinions ===
Chief Justice [[John Roberts]] wrote a separate [[concurring opinion]] "to address the important principles of [[judicial restraint]] and ''[[stare decisis]]'' implicated in this case".<ref name="Ref_b">[https://www.law.cornell.edu/supct/html/08-205.ZC.html Roberts opinion] et ibid.</ref> Roberts explained why the Supreme Court must sometimes overrule prior decisions. Had prior courts never gone against precedent, for example, "segregation would be legal, minimum wage laws would be unconstitutional, and the Government could wiretap ordinary criminal suspects without first obtaining warrants". Roberts's concurrence recited a plethora of case law in which the court had ruled against precedent. Ultimately, Roberts argued that "''stare decisis...'' counsels deference to past mistakes, but provides no justification for making new ones".<ref name="Ref_b" /> Roberts also briefly explained his reasoning for joining the majority. He explained: 

{{blockquote|"The [government's] ... theory, if accepted, would empower the Government to prohibit newspapers from running editorials or opinion pieces supporting or opposing candidates for office, so long as the newspapers were owned by corporations—as the major ones are. First Amendment rights could be confined to individuals, subverting the vibrant public discourse that is at the foundation of our democracy".<ref name="Ref_b" />}}


Justice [[Antonin Scalia]] also wrote a concurring opinion that addressed the dissent by Justice [[John Paul Stevens]], specifically with regard to the [[original understanding]] of the First Amendment. Scalia wrote that Stevens's dissent was "in splendid isolation from the text of the First Amendment... It never shows why 'the freedom of speech' that was the right of Englishmen did not include the freedom to speak in association with other individuals, including association in the corporate form." He further considered the dissent's exploration of the [[Constitutional Convention (United States)|Framers]]' views about the "role of corporations in society" to be misleading, and even if valid, irrelevant to the text of the Constitution. Scalia argued that the First Amendment was written in "terms of speech, not speakers" and that "Its text offers no foothold for excluding any category of speaker."<ref name="Ref_c">[https://www.law.cornell.edu/supct/html/08-205.ZC1.html Scalia opinion] at ibid.</ref> This interpretation supported the majority's contention that the Constitution does not allow the courts to separate corporations into media and non-media categories.<ref name="autogenerated2" />

Justice [[Clarence Thomas]], another member of the majority, also wrote a separate concurring opinion in which he disagreed with upholding the disclosure provisions of BCRA Sections 201 and 311. To protect the anonymity of contributors to organizations exercising free speech, Thomas would have struck down those reporting requirements, rather than allowing them to be challenged only on a case-by-case basis. Thomas's primary argument was that anonymous free speech is protected by the First Amendment and that making contributor lists public makes the contributors vulnerable to retaliation. Thomas also expressed concern that such retaliation could extend to retaliation ''by'' elected officials.<ref name="Ref_e">[https://www.law.cornell.edu/supct/html/08-205.ZX1.html Thomas opinion] at ibid.</ref>

=== Dissenting opinion ===
A dissenting opinion by Justice [[John Paul Stevens]]<ref name="Ref_d">[https://www.law.cornell.edu/supct/html/08-205.ZX.html Steven's opinion] at ibid.</ref> was joined by Justices [[Ruth Bader Ginsburg]], [[Stephen Breyer]], and [[Sonia Sotomayor]]. To emphasize his unhappiness with the majority, Stevens read part of his 90-page dissent from the bench.<ref>{{cite web|url=http://www.scotusblog.com/2010/01/citizens-united-v-fec-in-plain-english/|title=Citizens United v. FEC in plain English|author=McElroy, Linda|publisher=[[SCOTUSblog]]|date=January 22, 2010|access-date=October 4, 2011}}</ref> Stevens concurred in the court's decision to sustain BCRA's disclosure provisions but dissented from the principal holding. He argued that the majority ruling "threatens to undermine the integrity of elected institutions across the Nation. The path it has taken to reach its outcome will, I fear, do damage to this institution." He added: "A democracy cannot function effectively when its constituent members believe laws are being bought and sold."<ref>{{Cite web|url=https://www.law.cornell.edu/supct/html/08-205.ZX.html|title=Opinion of Stevens, J., Supreme Court of the United States. Citizens United, Appellant v. Federal Election Commission |last=Stevens|first=John Paul|date=January 21, 2010|website=Legal Information Institute|publisher=Cornell University Law School|access-date=March 12, 2016}}</ref> Stevens also argued that the court addressed a question not raised by the litigants when it found BCRA Section 203 to be facially unconstitutional, and that the majority "changed the case to give themselves an opportunity to change the law".<ref name="autogenerated2" /> [[Image:John Paul Stevens, SCOTUS photo portrait.jpg|175px|left|thumb|Justice Stevens, the author of the dissenting opinion]]Stevens argued that the court had long recognized that to deny Congress the power to safeguard against "the improper use of money to influence the result [of an election] is to deny to the nation in a vital particular the power of self protection".<ref>''[[Burroughs v. United States]]'', 290 U.S. 534 (1934)</ref> After recognizing that in ''[[Buckley v. Valeo]]'' the court had struck down portions of a broad prohibition of independent expenditures from any sources, Stevens argued that nevertheless ''Buckley'' recognized the legitimacy of "prophylactic" measures for limiting campaign spending and found the prevention of corruption to be a reasonable goal for legislation. Consequently, Stevens argued that ''Buckley'' left the door open for carefully-tailored future regulation. Stevens further argued that the majority opinion contradicted the reasoning of other campaign finance precedents including ''[[Austin v. Michigan Chamber of Commerce]]'' and ''[[McConnell v. FEC]].''<ref name="autogenerated2" />

On the matter of undue corporate influence on elections and spending on behalf of chosen candidates, Stevens cited ''[[First National Bank of Boston v. Bellotti]]'' and argued that the high court had "never suggested that such [[quid pro quo]] debts must take the form of outright vote buying or bribes". Again citing ''McConnell v. FEC'', he argued that independent expenditures were sometimes a factor in gaining political access and concluded that large independent expenditures generate ''more'' influence than direct campaign contributions.<ref name="autogenerated2" /> Furthermore, Stevens argued that corporations could threaten politicians with negative advertising to gain unprecedented leverage, citing ''[[Caperton v. A.T. Massey Coal Co.]]''<ref>''[[Caperton v. A.T. Massey Coal Co.]]'', 556 U.S. _ (2009)</ref> 

Hence, Stevens argued that the majority did not place enough emphasis on the need to prevent the [[appearance of corruption]] in elections. Earlier cases, including ''Buckley,'' recognized the importance of public confidence in democracy. Stevens cited recent data indicating that 80% of the public viewed corporate independent expenditures as a method to gain unfair legislative influence. With corporations able to spend far more to influence elections that any ordinary citizen, Stevens was concerned that the majority opinion would cause the citizenry to "lose faith in our democracy".<ref name="autogenerated2" /> 

Legal entities like corporations, Stevens wrote, are not "We the People" for whom our Constitution was established.<ref name=autogenerated2 /> Therefore, he argued, they should not be given speech protections under the First Amendment, which protects individual self-expression and self-realization. Corporate spending is the "furthest from the core of political expression" protected by the Constitution, he argued, citing ''Federal Election Commission v. Beaumont''.<ref>''Federal Election Commission v. Beaumont'', 539 U.S. 146 (2003)</ref><ref>{{Cite book|last=Garrett|first=R. Sam|url=https://books.google.com/books?id=SeQgxQEACAAJ|title=Campaign Finance Policy After Citizens United V. Federal Election Commission: Issues and Options for Congress|date=2010|publisher=Congressional Research Service|language=en}}</ref> According to Stevens, corporate spending on political advertising should be regulated as a business transaction, and evaluated on whether it conforms to the wishes of shareholders.<ref>{{Cite book|url=https://books.google.com/books?id=SUrMNAEACAAJ|title=Symposium: Citizens United V. Federal Election Commission: Implications for the American Electoral Process|date=2011|publisher=Cornell Law School|language=en}}</ref><ref>''[[Abood v. Detroit Board of Education]]'', 431 U.S. 209 (1977)</ref>

== Subsequent judicial developments ==
The ''Citizens United'' ruling represented a turning point on campaign finance, allowing unlimited election spending by corporations and labor unions, and setting the stage for ''Speechnow.org v. FEC'' (2010), which authorized the creation of [[Super PACs]], and ''[[McCutcheon v. FEC]]'' (2014), which struck down other campaign finance restrictions. The ruling also influenced the outcome of ''[[Arizona Free Enterprise Club's Freedom Club PAC v. Bennett]]'' (2011) in which the Supreme Court outlawed [[Publicly funded elections|public funding]] by states for candidates who were unable to compete with the corporate donations gained by their opponents.<ref>{{cite news |last=Mears |first=Bill |date=June 27, 2011 |title=Justices strike down taxpayer-supported campaign spending law |url=http://edition.cnn.com/2011/US/06/27/scotus.arizona.campaign.finance/index.html |access-date=October 16, 2012 |publisher=CNN}}</ref> While the long-term legacy of this case remains to be seen, an early study by one political scientist has concluded that ''Citizens United'' worked in favor of the electoral success of [[Republican Party (United States)|Republican]] candidates.<ref name=":0" /><ref name=":1">{{Cite journal |last1=Abdul-Razzak |first1=Nour |last2=Prato |first2=Carlo |last3=Wolton |first3=Stephane |date=2020-10-01 |title=After Citizens United: How outside spending shapes American democracy |journal=Electoral Studies |language=en |volume=67 |pages=102190 |doi=10.1016/j.electstud.2020.102190 |issn=0261-3794 |doi-access=free}}</ref><ref name=":5">{{Cite SSRN |title=Campaign Finance in the Age of Super PACs |last1=Cox |first1=Christian |date=2021-09-15 |ssrn=3794817}}</ref>

== Public reactions ==
The ''Citizens United'' ruling was highly controversial and remains a subject of widespread public discussion.<ref>{{cite magazine |last=Tharoor |first=Ishaan |date=December 13, 2010 |title=Top 10 Controversial Supreme Court Cases |url=http://content.time.com/time/specials/packages/article/0,28804,2036448_2036452_2036614,00.html |magazine=[[Time (magazine)|Time]]}}</ref><ref>{{cite web |last=Ehrenhalt |first=Alan |date=January 19, 2016 |title='Dark Money' by Jane Meyer |url=https://www.nytimes.com/2016/01/24/books/review/dark-money-by-jane-mayer.html |work=The New York Times}}</ref><ref>{{Cite web |title=Text-Only NPR.org: How Is Kavanaugh Likely To Rule On Critical Issues? Here's A Look At His Record |url=https://text.npr.org/s.php?sId=654713560 |access-date=2018-10-10 |website=text.npr.org}}</ref> 

===Support===
[[Citizens United (organization)|Citizens United]], upon its victory, said "Today's U.S. Supreme Court decision allowing Citizens United to air its documentary films and advertisements is a tremendous victory, not only for Citizens United but for every American who desires to participate in the political process."<ref name="Ref_2010">{{cite web |date=January 21, 2010 |title=Statement from David N. Bossie |url=http://citizensunited.org/blog.aspx?entryid=8225648 |archive-url=https://web.archive.org/web/20100127011535/http://www.citizensunited.org/blog.aspx?entryid=8225648 |archive-date=January 27, 2010 |access-date=January 22, 2010 |work=Citizens United Blog}}</ref> Republican politicians and advisors universally praised the Supreme Court's decision. According to Senate Minority Leader [[Mitch McConnell]], "For too long, some in this country have been deprived of full participation in the political process. With today's monumental decision, the Supreme Court took an important step in the direction of restoring the First Amendment rights of these groups by ruling that the Constitution protects their right to express themselves about political candidates and issues up until Election Day. By previously denying this right, the government was picking winners and losers. Our democracy depends upon free speech, not just for some but for all."<ref name="politico2010-01-21">{{cite web | url=http://www.politico.com/story/2010/01/pols-weigh-in-on-citizens-united-decision-031798 | title=Pols weigh in on Citizens United decision | publisher=Politico.com | date=January 21, 2010 | access-date=October 11, 2016}}</ref>

Republican campaign consultant [[Ed Rollins]] opined that the decision adds transparency to the election process and will make it more competitive.<ref name="Rollins2010">{{Cite news|last=Rollins|first=Ed |author-link=Ed Rollins |title=Another shock to the Washington system |url=http://www.cnn.com/2010/OPINION/01/21/rollins.campaign.rules.obsolete/index.html |publisher=CNN |date=January 22, 2010 |access-date=January 26, 2010}}</ref> Campaign finance attorney Cleta Mitchell, who had filed an [[amicus curiae]] brief on behalf of two advocacy organizations supporting Citizens United, wrote that "The Supreme Court has correctly eliminated a constitutionally flawed system that allowed media corporations... to freely disseminate their opinions about candidates using corporate treasury funds, while denying that constitutional privilege to Susie's Flower Shop Inc. ... The real victims of the corporate expenditure ban have been nonprofit advocacy organizations across the political spectrum."<ref name="WP-opinions">{{Cite news|title=Who is helped, or hurt, by the Citizens United decision? |newspaper=The Washington Post |date=January 24, 2010 |url=https://www.washingtonpost.com/wp-dyn/content/article/2010/01/22/AR2010012203874.html}}</ref>

[[Hans A. von Spakovsky]]''–''of [[The Heritage Foundation]] and former member of the [[Federal Election Commission]]''–''said "The Supreme Court has restored a part of the First Amendment that had been unfortunately stolen by Congress and a previously wrongly-decided ruling of the court."<ref name="Dinan2010">{{cite web|last=Dinan|first=Stephen |title=Divided court strikes down campaign money restrictions |work=[[The Washington Times]] |date=January 21, 2010 |url=http://www.washingtontimes.com/news/2010/jan/21/divided-court-strikes-down-campaign-money-restrict/?page=2 |page=2}}</ref> John Samples and Ilya Shapiro of the [[Cato Institute]] disagreed with the idea "that corporations had so much money that their spending would create vast inequalities in speech that would undermine democracy".<ref name="Samples2010">{{cite web|last1=Samples|first1=John |last2=Shapiro|first2=Ilya |title=Free Speech for All |publisher=[[Cato Institute]] |date=January 21, 2010 |url=http://www.cato.org/pub_display.php?pub_id=11159}}</ref> 

Law professor [[Bradley A. Smith]]''–''former chairman of the FEC and founder of the [[Institute for Free Speech]]''–''wrote that the opponents of political free speech are "incumbent politicians" who "are keen to maintain a chokehold on such speech". Empowering "small and midsize corporations—and every incorporated mom-and-pop falafel joint, local firefighters' union, and environmental group—to make its voice heard" frightens them.<ref name="Smith2010">{{Cite journal|last=Smith|first=Bradley |title=The Citizens United Fallout, Democrats plan to redouble their efforts to stifle corporate free speech |url=http://www.city-journal.org/2010/eon0125bs.html |journal=[[City Journal (New York)|City Journal]] |date=January 25, 2010}}</ref> Campaign finance expert Jan Baran, a member of the [[Commission on Federal Ethics Law Reform]], wrote that "The history of campaign finance reform is the history of incumbent politicians seeking to muzzle speakers, any speakers, particularly those who might publicly criticize them and their legislation. It is a lot easier to legislate against unions, gun owners, 'fat cat' bankers, health insurance companies and any other industry or 'special interest' group when they can't talk back."<ref name="Baran">{{cite news |last=Baran|first=Jan Witold |title=Stampede Toward Democracy |work=The New York Times |date=January 25, 2010 |url=https://www.nytimes.com/2010/01/26/opinion/26baran.html}}</ref>

The editorial board of the ''[[San Antonio Express-News]]'' praised the ruling for overturning the BCRA exception for media corporations from the ban on corporate electioneering, writing that it "makes no sense" that the paper could make endorsements up until the day of the election but advocacy groups could not. "While the influence of money on the political process is troubling and sometimes corrupting, abridging political speech is the wrong way to counterbalance that influence."<ref name="Ref_2010a">{{cite web | title=High court ruling protects speech | url=http://www.mysanantonio.com/opinion/82636522.html | work=San Antonio Express-News Editorial Board | publisher=Hearst Newspapers | date=January 26, 2010 | access-date=January 26, 2010}}{{dead link|date=August 2012}}</ref>

===Opposition===
President [[Barack Obama]] stated that the decision "gives the special interests and their lobbyists even more power in Washington—while undermining the influence of average Americans who make small contributions to support their preferred candidates".<ref name="Ref_2010b">{{cite news|title=Obama Criticizes Campaign Finance Ruling |url=http://politicalticker.blogs.cnn.com/2010/01/21/obama-criticizes-campaign-finance-ruling |archive-url=https://archive.today/20130102084233/http://politicalticker.blogs.cnn.com/2010/01/21/obama-criticizes-campaign-finance-ruling |url-status=dead |archive-date=January 2, 2013 |work=CNN Political Ticker |publisher=[[Turner Broadcasting System, Inc.]] |date=January 20, 2010 |access-date=January 22, 2010}}</ref> Obama later stated that "this ruling strikes at our democracy itself" and "I can't think of anything more devastating to the public interest".<ref name="Superville2010">{{cite news|last=Superville|first=Darlene |title=President Blasts Supreme Court Over Citizens United Decision |url=https://www.huffingtonpost.com/2010/01/23/obama-weekly-address-vide_n_434082.html |work=[[The Huffington Post]] |date=January 23, 2010 |access-date=January 23, 2010}}</ref> Just days after the ruling, Obama condemned the decision during his [[2010 State of the Union Address]], stating that, "Last week, the Supreme Court reversed a century of law to open the floodgates for special interests—including foreign corporations—to spend without limit in our elections. Well, I don't think American elections should be bankrolled by America's most powerful interests, or worse, by foreign entities."<ref>{{cite news |last=Silverleib |first=Alan |date=January 28, 2010 |title=Gloves come off after Obama rips Supreme Court ruling |url=http://www.cnn.com/2010/POLITICS/01/28/alito.obama.sotu/index.html?hpt=Sbin |url-status=live |archive-url=https://web.archive.org/web/20100213162929/http://www.cnn.com/2010/POLITICS/01/28/alito.obama.sotu/index.html?hpt=Sbin |archive-date=February 13, 2010 |access-date=February 22, 2010 |publisher=CNN}}</ref> On television, the camera shifted to a shot of the Supreme Court Justices in the front row directly in front of the President while he was making this statement, and Justice [[Samuel Alito]] mouthed the words "Not true".<ref>{{cite web|url=https://www.npr.org/sections/thetwo-way/2010/01/if_alito_did_say_not_true_abou.html |title=If Alito Did Say 'Not True' About Obama's Claim, He May Have Had A Point – The Two-Way – Breaking News, Analysis Blog |publisher=NPR |date=January 28, 2010 |access-date=February 22, 2010 |archive-url=https://web.archive.org/web/20100408141533/http://www.npr.org/blogs/thetwo-way/2010/01/if_alito_did_say_not_true_abou.html| archive-date= April 8, 2010 |url-status=live}}</ref><ref>{{cite web|url=http://buzz.yahoo.com/article/1:95ec266b244de718b80c652a08af06fa:81fc3961c4ce20668b006dd8b72852c1/Alito-Mouths-NOT-TRUE-At-State-Of-The-Union-VIDEO |title=Alito Mouths 'NOT TRUE' At State Of The Union (Video) |publisher=Huffington Post – Yahoo! Buzz.yahoo.com |date=January 28, 2010 |access-date=February 22, 2010 |archive-url=https://web.archive.org/web/20100131084825/http://buzz.yahoo.com/article/1%3A95ec266b244de718b80c652a08af06fa%3A81fc3961c4ce20668b006dd8b72852c1/Alito-Mouths-NOT-TRUE-At-State-Of-The-Union-VIDEO |archive-date=January 31, 2010 }}</ref><ref>{{cite news|url=http://www.cbsnews.com/video/watch/?id=6154907n |title=Alito: 'Simply Not True' |publisher=CCBS News |date=January 29, 2010 |access-date=February 22, 2010 |archive-url=https://web.archive.org/web/20100202204723/http://www.cbsnews.com/video/watch/?id=6154907n |archive-date=February 2, 2010 |url-status=live}}</ref>

Democratic Senator [[Russ Feingold]], a lead sponsor of the BCRA, stated "This decision was a terrible mistake. Presented with a relatively narrow legal issue, the Supreme Court chose to roll back laws that have limited the role of corporate money in federal elections since Teddy Roosevelt was president."<ref name=Hunt/> Representative [[Alan Grayson]] stated that it was "the worst Supreme Court decision since the ''[[Dred Scott v. Sandford|Dred Scott case]]'', and that the court had opened the door to political bribery and corruption in elections to come.<ref name="Baumann2010">{{cite web|last=Baumann |first=Nick |title=Grayson: Court's Campaign Finance Decision "Worst Since Dred Scott" |url=http://motherjones.com/mojo/2010/01/grayson-courts-campaign-finance-decision-worst-dredd-scott |work=Mother Jones |publisher=Mother Jones and the Foundation for National Progress |date=January 22, 2010 |access-date=January 26, 2010}}</ref> Senator [[John McCain]], a co-crafter of the BCRA, said "there's going to be, over time, a backlash... when you see the amounts of union and corporate money that's going to go into political campaigns".<ref name="Amick">{{cite news|last=Amick |first=John |title=McCain skeptical Supreme Court decision can be countered |url=http://voices.washingtonpost.com/44/2010/01/mccain-skeptical-supreme-court.html?wprss=44 |archive-url=https://archive.today/20130105042540/http://voices.washingtonpost.com/44/2010/01/mccain-skeptical-supreme-court.html?wprss=44 |url-status=dead |archive-date=January 5, 2013 |newspaper=The Washington Post |date=January 24, 2010}}</ref> McCain was "disappointed by the decision of the Supreme Court and the lifting of the limits on corporate and union contributions" but not surprised by the decision, saying that "It was clear that Justice Roberts, Alito and Scalia, by their very skeptical and even sarcastic comments, were very much opposed to BCRA."<ref name="Hunt">{{cite web|last=Hunt |first=Kasie |title=John McCain, Russ Feingold diverge on court ruling |url=http://www.politico.com/news/stories/0110/31810.html |work=Politico |date=January 21, 2010}}</ref> 

Consumer activist [[Ralph Nader]] condemned the ruling, saying that "With this decision, corporations can now directly pour vast amounts of corporate money, through independent expenditures, into the electoral swamp already flooded with corporate campaign PAC contribution dollars."<ref name="Nader2010">{{cite web|last=Nader |first=Ralph |author-link=Ralph Nader |title=Time to Reign in Out-of-Control Corporate Influences on Our Democracy |date=January 22, 2010 |url=http://www.nader.org/index.php?/archives/2168-Time-to-Reign-in-Out-of-Control-Corporate-Influences-on-Our-Democracy.html}}</ref><ref name="Nader2010a">{{cite web|last=Nader |first=Ralph |author-link=Ralph Nader |title=The Supremes Bow to King Corporation |publisher=[[CounterPunch]] |date=January 22, 2010 |url=http://www.counterpunch.org/nader01222010.html |archive-url=https://web.archive.org/web/20100126093231/http://www.counterpunch.org/nader01222010.html |archive-date=January 26, 2010 }}</ref> When discussing the ruling and related developments, former President [[Jimmy Carter]] called the United States "an oligarchy with unlimited political bribery" in an interview with [[Thom Hartmann]].<ref>{{Cite web|last=Schwarz|first=Jon|date=July 30, 2015|title=Jimmy Carter: The U.S. Is an "Oligarchy With Unlimited Political Bribery"|url=https://theintercept.com/2015/07/30/jimmy-carter-u-s-oligarchy-unlimited-political-bribery/|website=The Intercept}}</ref> Retired Supreme Court Justice [[Sandra Day O'Connor]], whose opinions had changed from dissenting in ''Austin v. Michigan State Chamber of Commerce'' to co-authoring (with Stevens) the majority opinion in ''McConnell v. FEC'' twelve years later, criticized the decision only obliquely, but warned, "In invalidating some of the existing checks on campaign spending, the majority in ''Citizens United'' has signaled that the problem of campaign contributions in judicial elections might get considerably worse and quite soon."<ref name="Liptak2010">{{cite news| last=Liptak | first=Adam | title=O'Connor Mildly Criticizes Court's Campaign Finance Decision | url=http://thecaucus.blogs.nytimes.com/2010/01/26/oconnor-mildly-criticizes-courts-campaign-finance-decision/?hp | work=The New York Times | date=January 26, 2010}}</ref>

Constitutional law scholar [[Laurence H. Tribe]] wrote that the decision elevates "a business corporation as merely another way that individuals might choose to organize their association with one another to pursue their common expressive aims is worse than unrealistic; it obscures the very real injustice and distortion entailed in the phenomenon of some people using other people's money to support candidates they have made no decision to support, or to oppose candidates they have made no decision to oppose."<ref name="Tribe2010">{{cite web| last=Tribe | first=Laurence | title=What Should Congress Do About Citizens United? An analysis of the ruling and a possible legislative response | url=http://www.scotusblog.com/2010/01/what-should-congress-do-about-citizens-united/ | work=[[SCOTUSblog]] | date=January 24, 2010}}</ref> [[Cass Sunstein]] of [[Harvard University]] listed ''Citizens United'' as the "worst Supreme Court decision since 1960", noting that the decision is "undermining our system of democracy itself."<ref>{{Cite magazine|url=https://time.com/4056051/worst-supreme-court-decisions/|title=The Worst Supreme Court Decisions Since 1960|first=Andrea|last=Sachs|magazine=[[Time (magazine)|Time]]}}</ref>

''[[The New York Times]]'' stated in an editorial, "The Supreme Court has handed lobbyists a new weapon. A lobbyist can now tell any elected official: if you vote wrong, my company, labor union or interest group will spend unlimited sums explicitly advertising against your re-election."<ref name="Kirkpatrick">{{Cite news| last=Kirkpatrick | first=David D.| title=Lobbyists Get Potent Weapon in Campaign Financing | url=https://www.nytimes.com/2010/01/22/us/politics/22donate.html | work=The New York Times | date=January 22, 2010 | access-date=January 27, 2010}}</ref> [[Jonathan Alter]] called it the "most serious threat to American democracy in a generation".<ref name="Alter">{{Cite journal| last=Alter | first=Jonathan | author-link=Jonathan Alter | title=High Court Hypocrisy: Dick Durbin's got a good idea | journal=[[Newsweek]] | publisher=Newsweek, Inc. | date= February 1, 2010 | url=http://www.newsweek.com/id/232147 | access-date=January 27, 2010}}</ref> ''[[The Christian Science Monitor]]'' wrote that the court had declared "outright that corporate expenditures cannot corrupt elected officials, that influence over lawmakers is not corruption, and that appearance of influence will not undermine public faith in our democracy".<ref name="Ref_j">{{cite journal| title=A Bad Day for Democracy|journal=[[The Christian Science Monitor]] |date=January 22, 2010 | url=http://www.csmonitor.com/Commentary/Opinion/2010/0122/Supreme-Court-s-campaign-ruling-a-bad-day-for-democracy| access-date=January 22, 2010}}</ref>
=== Polls ===
An ABC–''Washington Post'' poll conducted shortly after the ''Citizens United'' ruling showed that 80% of those surveyed opposed (and 65% strongly opposed) the ruling, with the pollsters interpreting the results as: "corporations and unions can spend as much money as they want to help political candidates win elections". Additionally, 72% supported "an effort by Congress to reinstate limits on corporate and union spending on election campaigns". The poll showed large majority support from Democrats, Republicans, and independents.<ref name="Ref_k">[https://www.washingtonpost.com/wp-srv/politics/polls/postpoll_021010.html Washington Post-ABC News poll] of February 4–8, 2010.</ref><ref name="Ref_l">Gary Langer, [http://blogs.abcnews.com/thenumbers/2010/02/in-supreme-court-ruling-on-campaign-finance-the-public-dissents.html In Supreme Court Ruling on Campaign Finance, the Public Dissents], [[ABC News (United States)|ABC News]], February 17, 2010.</ref><ref name="Ref_m">Dan Eggan, [https://www.washingtonpost.com/wp-dyn/content/article/2010/02/17/AR2010021701151.html Poll: Large majority opposes Supreme Court's decision on campaign financing], ''[[The Washington Post]]'', February 17, 2010.</ref>

A [[Gallup Poll]] conducted in 2009, after oral arguments but publicized after the Supreme Court ruling, resulted in somewhat different conclusions. The poll found that 57% of those surveyed "agreed that money given to political candidates is a form of free speech" and 55% percent agreed that the "same rules should apply to individuals, corporations and unions". In the same poll, however, 52% of respondents supported limits on campaign contributions over financial support of campaigns and 76% thought the government should be able to place limits on corporate or union donations.<ref name="Ref_n">Lydia Saad, [http://www.gallup.com/poll/125333/Public-Agrees-Court-Campaign-Money-Free-Speech.aspx Public Agrees With Court: Campaign Money Is "Free Speech" but have mixed views on other issues at heart of new Supreme Court ruling], Gallup, January 22, 2010.</ref><ref name="Ref_o">Jordan Fabian, [https://thehill.com/blogs/blog-briefing-room/news/59574-poll-public-agrees-with-principles-of-campaign-finance-decision/ Poll: Public agrees with principles of campaign finance decision], [[The Hill (newspaper)|The Hill]], January 23, 2010.</ref>

Separate polls commissioned by various conservative organizations, including [[Citizens United (organization)|Citizens United]] and the [[Institute for Free Speech]], using different wording, found support for the decision.<ref name="Ref_p">{{cite web|url=http://www.citizensunited.org/press.aspx?entryid=6526738 |title=Citizens United :: Press Releases :: Citizens United Releases Results of National Opinion Poll on Campaign Finance "Reform" |date=April 17, 2010 |url-status=bot: unknown |archive-url=https://web.archive.org/web/20100417044044/http://www.citizensunited.org/press.aspx?entryid=6526738 |archive-date=April 17, 2010 }}</ref> In particular, a Center for Competitive Politics poll found that 51% of respondents believed that Citizens United should have a right to air ads promoting ''Hillary: The Movie''. The poll also found that only 22% had heard of the Supreme Court ruling.<ref name="Ref_q">{{cite web|url=http://www.campaignfreedom.org/docLib/20100304_CCPpoll03042010.pdf |title=Campaignfreedom.org |archive-url=https://web.archive.org/web/20110727220907/http://www.campaignfreedom.org/docLib/20100304_CCPpoll03042010.pdf |archive-date=July 27, 2011 }}</ref> Polling conducted by Ipsos in 2017 found that 48% of Americans oppose the decision and 30% support it, with the remainder having no opinion. The poll also found that 57% percent of Americans favored "limits on the amount of money super PACs can raise and spend".<ref>Chris Jackson, [https://www.ipsos.com/en-us/news-polls/center-for-public-integrity-2017-08-31 Majority of Americans Support Campaign Finance Reform] {{Webarchive|url=https://web.archive.org/web/20180925060651/https://www.ipsos.com/en-us/news-polls/center-for-public-integrity-2017-08-31 |date=September 25, 2018 }}, August 31, 2017.</ref>

==Legislative responses==

=== Federal ===
In February 2010, shortly after the Supreme Court ruling, Senator [[Chuck Schumer|Charles E. Schumer]] and Representative [[Chris Van Hollen]] outlined legislation aimed at undoing the decision.<ref name="Eggen2010">{{Cite news|first=Dan |last=Eggen |title=Top Democrats Seek Broad Disclosure on Campaign Financing |newspaper=[[The Washington Post]] |date=April 29, 2010 |url= https://www.washingtonpost.com/wp-dyn/content/article/2010/04/29/AR2010042903165.html}}</ref><ref name="nyt100211">{{Cite news | title = Democrats Try to Rebuild Campaign-Spending Barriers | first = David D.| last = Kirkpatrick | url = https://www.nytimes.com/2010/02/12/us/politics/12citizens.html | work = The New York Times | date = February 11, 2010 | page = A19 | access-date = February 14, 2010 | quote = Congressional Democrats outlined legislation Thursday aimed at undoing a recent Supreme Court decision that allows corporations and interest groups to spend freely on political advertising. }}</ref> In June the [[DISCLOSE Act]] passed in the House of Representatives but failed in the Senate. It would have required additional disclosure by corporations of their campaign expenditures. The law, if passed, would also have prohibited political spending by American companies with twenty percent or more foreign ownership, and by most government contractors.<ref name="Ref_r">{{cite news|url=https://thehill.com/homenews/house/164626-house-approves-campaign-finance-measure-by-219-206/|title=House approves campaign finance measure by 219-206|first=Ashley|last=Perks|newspaper=The Hill |date=June 25, 2010}}</ref> Also in 2010, Senator [[Dick Durbin]] (D-IL) proposed that laws on corporate governance be amended to assure that shareholders vote on political expenditures.<ref name="Alter" />

Representative [[Donna Edwards]] and Maryland Democratic State Senator [[Jamie Raskin]], have circulated petitions to reverse the decision by means of constitutional amendment.<ref name="PubRec">{{Cite news |date=January 21, 2010 |title=Group Calls For Constitutional Amendment to Overturn High Court's Campaign Finance Ruling |url=http://pubrecord.org/multimedia/6674/congresswoman-professor-movement/ |archive-url=https://web.archive.org/web/20100125193333/http://pubrecord.org/multimedia/6674/congresswoman-professor-movement/ |archive-date=January 25, 2010 |access-date=January 26, 2010 |publisher=[[The Public Record (newspaper)|The Public Record]] |df=mdy-all}}</ref> Representative [[Leonard Boswell]] introduced legislation to amend the constitution.<ref name="II">{{Cite news |last=Hancock |first=Jason |date=January 21, 2010 |title=Boswell pushes constitutional amendment to overturn SCOTUS ruling |url=http://iowaindependent.com/26145/boswell-pushes-constitutional-amendment-to-overturn-scotus-ruling |archive-url=https://web.archive.org/web/20100124104330/http://iowaindependent.com/26145/boswell-pushes-constitutional-amendment-to-overturn-scotus-ruling |archive-date=January 24, 2010 |access-date=January 26, 2010 |work=The [[Iowa Independent]]}}</ref> President [[Barack Obama]]<ref name="WP20120829">{{cite news |last=Weiner |first=Rachel |date=August 29, 2012 |title=Obama suggests constitutional amendment in Reddit chat |url=https://www.washingtonpost.com/blogs/election-2012/wp/2012/08/29/in-reddit-chat-obama-suggests-constitutional-amendment-to-overturn-citizens-united/ |archive-url=https://web.archive.org/web/20120901131059/http://www.washingtonpost.com/blogs/election-2012/wp/2012/08/29/in-reddit-chat-obama-suggests-constitutional-amendment-to-overturn-citizens-united/ |archive-date=September 1, 2012 |access-date=November 1, 2012 |newspaper=The Washington Post}}</ref> and Senator [[John Kerry]] also called for an amendment to overrule the decision.<ref name="Crabtree2010">{{cite web |last=Crabtree |first=Susan |date=February 2, 2010 |title=Sen. Kerry backs changing Constitution to deal with Supreme Court decision |url=https://thehill.com/homenews/senate/60397-sen-kerry-backs-changing-constitution-to-deal-with-supreme-court-decision/ |access-date=February 6, 2010 |work=The Hill |publisher=Capitol Hill Publishing Corp.}}</ref> In 2011 Senator [[Bernie Sanders]] proposed the Saving American Democracy Amendment, which would reverse the court's ruling.<ref>{{cite news |last=Remsen |first=Nancy |date=December 8, 2011 |title=Sen. Bernie Sanders, I–Vt., offers constitutional amendment on corporate "citizenship" |url=http://blogs.burlingtonfreepress.com/politics/2011/12/08/sen-bernie-sanders-i-vt-offers-constitutional-amendment-on-corporate-citizenship/ |archive-url=https://archive.today/20120712225339/http://blogs.burlingtonfreepress.com/politics/2011/12/08/sen-bernie-sanders-i-vt-offers-constitutional-amendment-on-corporate-citizenship/ |archive-date=July 12, 2012 |work=[[The Burlington Free Press]]}}</ref> In 2015 Sanders said that "the foundations of American Democracy are being undermined" and called for sweeping campaign finance reform.<ref>{{Cite web |date=September 28, 2015 |title=Bernie Sanders' litmus test: Overturn Citizens United |url=http://www.cnn.com/2015/09/28/politics/bernie-sanders-chicago-koch-brothers-scotus/index.html |access-date=September 29, 2015 |website=CNNPolitics.com}}</ref> Sanders has repeated such calls in the years since.<ref>{{Cite web |title=State of the Union Response 2018 |url=https://www.sanders.senate.gov/newsroom/press-releases/state-of-the-union-response-2018 |url-status=dead |archive-url=https://web.archive.org/web/20180922051512/https://www.sanders.senate.gov/newsroom/press-releases/state-of-the-union-response-2018 |archive-date=September 22, 2018 |access-date=2018-10-10 |website=Sen. Bernie Sanders |language=en-US}}</ref><ref>{{Citation |last=Sanders |first=Bernie |title=Speech Ahead of Senate Final Vote on Kavanaugh Confirmation |date=2018-10-05 |url=https://www.youtube.com/watch?v=rFpx0vxkn8s |access-date=2018-10-10 |archive-url=https://web.archive.org/web/20181006200731/https://www.youtube.com/watch?v=rFpx0vxkn8s |archive-date=2018-10-06}}</ref>

===States===
''The New York Times'' reported that 24 states with laws prohibiting or limiting independent expenditures by unions and corporations would have to change their campaign finance laws because of the ruling.<ref name="Urbina2010">{{Cite news |last=Urbina |first=Ian |date=January 22, 2010 |title=24 States' Laws Open to Attack After Campaign Finance Ruling |url=https://www.nytimes.com/2010/01/23/us/politics/23states.html |access-date=January 23, 2010 |work=The New York Times}}</ref> After ''Citizens United'', numerous state legislatures raised their limits on contributions to candidates and parties.<ref name="CCP2013">{{cite news |last=Wachob |first=Luke |date=May 9, 2014 |title=2013 State Legislative Trends: Campaign Contribution Limits Increase in Nine States |url=http://www.campaignfreedom.org/2014/05/09/legislative-review-2013-state-legislative-trends-campaign-contribution-limits-increase-in-nine-states/ |url-status=dead |archive-url=https://web.archive.org/web/20141216200933/http://www.campaignfreedom.org/2014/05/09/legislative-review-2013-state-legislative-trends-campaign-contribution-limits-increase-in-nine-states/ |archive-date=December 16, 2014 |access-date=December 16, 2014}}</ref> Members of 16 state legislatures have called for a [[constitutional amendment]] to reverse the Supreme Court's decision.<ref>{{cite news|last=Blumenthal|first=Paul|title=Citizens United Constitutional Amendment: New Jersey Legislature Seeks Reversal Of Ruling|url=https://www.huffingtonpost.com/2012/10/18/citizens-united-amendment-new-jersey_n_1981950.html|newspaper=Huffington Post|date=October 18, 2012}}</ref> Most of these are non-binding resolutions, but three states—Vermont, California, and Illinois—called for an [[Convention to propose amendments to the United States Constitution|Article V Convention]] to draft and propose a federal constitutional amendment to overturn ''Citizens United''. (Thirty-four states are needed to call an Article V convention.)<ref>{{cite news|last=Reid|first=Brandon|title=Illinois third state to call for constitutional convention to overturn 'Citizens United'|url=http://rockrivertimes.com/2014/12/04/illinois-third-state-to-call-for-constitutional-convention-to-overturn-citizens-united/|newspaper=[[Rock River Times]]|date=December 4, 2014|access-date=December 16, 2014|archive-url=https://web.archive.org/web/20141208193632/http://rockrivertimes.com/2014/12/04/illinois-third-state-to-call-for-constitutional-convention-to-overturn-citizens-united/|archive-date=December 8, 2014}}</ref> In [[Minnesota]], the state senate passed a similar resolution but it did not survive further discussions by the state assembly.<ref>{{cite web|url=http://legiscan.com/MN/bill/SF17/2013 |title=MN SF17 &#124; 2013-2014 &#124; 88th Legislature |publisher=LegiScan |access-date=August 1, 2015}}</ref> On the  local level, Washington, D.C., and 400 other municipalities passed resolutions requesting a federal constitutional amendment.<ref>{{cite web|url=http://www.united4thepeople.org/local.html |title=State and Local Support &#124; United For The People |publisher=United4thepeople.org |access-date=August 1, 2015}}</ref>

==Political impact==
Critics predicted that the ''Citizens United'' ruling would "bring about a new era of corporate influence in politics", allowing companies to "buy elections" to promote their financial interests. Instead, large expenditures, usually through "Super PACS", have come from "a small group of billionaires", based largely on ideology.<ref name="Mider-20-1-2016">{{cite news|last1=Mider|first1=Zachary|date=January 20, 2016|title=What Kind of Man Spends Millions to Elect Ted Cruz?|agency=Bloomberg|url=https://www.bloomberg.com/politics/features/2016-01-20/what-kind-of-man-spends-millions-to-elect-ted-cruz-|access-date=January 28, 2016|archive-url=https://web.archive.org/web/20160120203452/https://www.bloomberg.com/politics/features/2016-01-20/what-kind-of-man-spends-millions-to-elect-ted-cruz-|archive-date=January 20, 2016|url-status=live}}</ref> ''The New York Times'' asked seven academics to opine on how corporate money would reshape politics as a result of the court's decision.<ref name="NYTdebate">{{cite news |date=January 21, 2010 |title=How Corporate Money Will Reshape Politics: Restoring Free Speech in Elections |url=http://roomfordebate.blogs.nytimes.com/2010/01/21/how-corporate-money-will-reshape-politics |access-date=January 21, 2010 |work=The New York Times |department=Room for Debate |archive-url=https://web.archive.org/web/20100124051102/http://roomfordebate.blogs.nytimes.com/2010/01/21/how-corporate-money-will-reshape-politics |archive-date=January 24, 2010 |url-status=live}}</ref> Three wrote that the effects would be minimal or positive: Christopher Cotton wrote that "There may be very little difference between seeing eight ads or seeing nine ads... And, voters recognize that richer candidates are not necessarily the better candidates, and in some cases, the benefit of running more ads is offset by the negative signal that spending a lot of money creates.<ref name="NYTdebate" /> [[Eugene Volokh]] stated that the "most influential actors in most political campaigns" are media corporations which "overtly editorialize for and against candidates, and also influence elections by choosing what to cover and how to cover it". Holding that corporations like [[Exxon]] would fear alienating voters by supporting candidates, the decision really meant that voters would hear "more messages from more sources".<ref name="NYTdebate" />

According to a 2020 report from [[OpenSecrets]], between 2010 and 2020, the ten largest donors and their spouses spent a total of $1.2&nbsp;billion on federal elections. In the 2018 elections, this group accounted for around 7% of all election-related giving, up from less than 1% a decade prior. Over the decade, election-related spending by non-partisan independent groups jumped to $4.5&nbsp;billion, whereas from 1990 to 2010 the total spending under that category was just $750&nbsp;million. Outside spending surpassed candidate spending in 126 races since the ruling compared to only 15 in the five election cycles prior. Groups that did not disclose their donors spent $963&nbsp;million in the decade following the ruling, compared to $129&nbsp;million in the decade prior. Non-partisan outside spending as a percentage of total election spending increased from 6% in 2008 to nearly 20% in 2018. During the 2016 election cycle, [[Political action committee|Super PACs]] spent more than $1&nbsp;billion, nearly twice that of every other category of contributors combined. In 2018, over 95% of super PAC money came from the top 1% of donors.<ref name=":2">{{Cite web |last= |last2= |first2= |last3= |last4= |first4= |last5= |date=2020-01-14 |title=More money, less transparency: A decade under Citizens United |url=https://www.opensecrets.org/news/reports/a-decade-under-citizens-united |access-date=2023-08-23 |website=OpenSecrets |language=en-US|archive-url=https://web.archive.org/web/20200114121849/https://www.opensecrets.org/news/reports/a-decade-under-citizens-united|archive-date=January 14, 2020|url-status=live}}</ref> 

''Citizens United'' has often been credited for the creation of Super PACs''–''political action committees that make no direct financial contributions to candidates or parties but instead spend money on advertising, and can in turn accept unlimited contributions from individuals, corporations, and unions.<ref>{{cite news|title=Super-Soft Money: How Justice Kennedy paved the way for 'SuperPACS' and the return of soft money|url=http://www.slate.com/articles/news_and_politics/jurisprudence/2011/10/citizens_united_how_justice_kennedy_has_paved_the_way_for_the_re.html|access-date=October 13, 2012|newspaper=[[Slate (magazine)|Slate]]|date=October 25, 2012|author=Richard L. Hasen|archive-url=https://web.archive.org/web/20111025183717/http://www.slate.com/articles/news_and_politics/jurisprudence/2011/10/citizens_united_how_justice_kennedy_has_paved_the_way_for_the_re.html|archive-date=October 25, 2011|url-status=live}}</ref> According to a 2021 study, the ruling weakened political parties while strengthening single-issue advocacy groups and Super PACs funded by billionaires with pet issues. The ruling made it easier for self-promoting politicians to undermine political processes and democratic norms to promote themselves by soliciting funds from such committees.<ref>{{Cite book|last=Popkin|first=Samuel L.|url=https://books.google.com/books?id=UhklEAAAQBAJ|title=Crackup: The Republican Implosion and the Future of Presidential Politics|date=2020|publisher=Oxford University Press|isbn=978-0-19-091382-3|language=en}}</ref>

''Citizens United'' also allowed incorporated [[501c4|501(c)(4)]] public advocacy groups (such as the [[National Rifle Association of America]], the [[Sierra Club]], or [[Citizens United (organization)|Citizens United]] itself) to make expenditures in political races. Such groups may not, under the tax code, have a ''primary'' purpose of engaging in electoral advocacy but they can advertise on behalf of larger political issues. A number of partisan organizations such [[Crossroads Grassroots Policy Strategies]] and 21st Century Colorado have since registered as tax-exempt 501(c)(4) groups and have engaged in substantial political spending.<ref>{{cite news|last=Berman|first=Ari|title=The .000063% Election|url=https://www.huffingtonpost.com/ari-berman/super-pacs-2012_b_1281716.html|access-date=October 13, 2012|newspaper=The Huffington Post|date=February 16, 2012|archive-url=https://web.archive.org/web/20120217031059/https://www.huffingtonpost.com/ari-berman/super-pacs-2012_b_1281716.html|archive-date=February 17, 2012|url-status=live}}</ref><ref>{{cite web |url=http://www.colbertsuperpac.com/ |title=Colbert Super PAC – Making a Better Tomorrow, Tomorrow |website=[[Colbert Super PAC]] |url-status=dead |access-date=February 22, 2012 |archive-date=April 30, 2012 |archive-url=https://web.archive.org/web/20120430074528/http://www.colbertsuperpac.com/ }}</ref> This has led to claims of large secret donations,<ref>{{cite web|author=Dan Glaun |url=https://www.opensecrets.org/news/2012/08/super-pacs-funneling-money-through.html |title=Super PACs Utilize Secretive Nonprofits to Hide Funding in Pennsylvania, Utah &#124; OpenSecrets Blog |publisher=Opensecrets.org |date=August 13, 2012 |access-date=August 1, 2015 |archive-url=https://web.archive.org/web/20120815192607/https://www.opensecrets.org/news/2012/08/super-pacs-funneling-money-through.html |archive-date=August 15, 2012 |url-status=live}}</ref><ref>{{cite web|author=Emma Schwartz |url=https://www.pbs.org/wgbh/pages/frontline/government-elections-politics/big-sky-big-money/the-rules-that-govern-501c4s/ |title=The Rules That Govern 501(c)(4)s &#124; Big Money 2012 &#124; Frontline |publisher=PBS |date=October 30, 2012 |access-date=August 1, 2015}}</ref><ref>{{cite web|url=http://truth-out.org/news/item/10289-secret-donors-vs-freedom-of-speech-the-tricky-task-of-reforming-election-abuse-by-nonprofits-part-two |title=Secret Donors vs. First Amendment: The Tricky Task of Reforming Election Abuse by Nonprofits (Part Two) |publisher=Truth-out.org |date=September 22, 2014 |access-date=August 1, 2015}}</ref> and questions about whether such groups should be required to disclose their donors, which they were required to do before the ''Citizens United'' ruling.<ref>{{Cite web|url=https://www.nytimes.com/2016/01/24/books/review/dark-money-by-jane-mayer.html|title='Dark Money', by Jane Mayer|first=Alan|last=Ehrenhalt|date=January 19, 2016|work=The New York Times}}</ref> 

While the long-term legacy of the ruling remains to be seen, studies by political scientists have concluded that ''Citizens United'' worked in favor of the electoral success of [[Republican Party (United States)|Republican]] candidates.<ref name=":0" /><ref name=":1" /><ref name=":5" /> One study by the [[University of Chicago]], [[Columbia University]], and the [[London School of Economics]] found "that ''Citizens United'' increased the GOP's average seat share in the state legislature[s] by five percentage points. That is a large effect—large enough that, were it applied to the past twelve Congresses, partisan control of the House would have switched eight times."<ref>{{Cite news|url=https://www.washingtonpost.com/news/monkey-cage/wp/2017/02/24/how-citizens-united-gave-republicans-a-bonanza-of-seats-in-u-s-state-legislatures/|title=How Citizens United gave Republicans a bonanza of seats in U.S. state legislatures|newspaper=The Washington Post|language=en|access-date=2018-10-24}}</ref><ref>{{Cite journal|last1=Abdul-Razzak|first1=Nour|last2=Prato|first2=Carlo|last3=Wolton|first3=Stephane|date=2017|title=How Outside Spending Shapes American Democracy|journal=SSRN Working Paper Series|language=en|doi=10.2139/ssrn.2823778|issn=1556-5068|ssrn=2823778|s2cid=157626829}}</ref> A 2016 study in ''[[The Journal of Law and Economics]]'' found "that ''Citizens United'' is associated with an increase in Republicans' election probabilities in state house races of approximately 4 percentage points overall and 10 or more percentage points in several states. We link these estimates to on-the-ground evidence of significant spending by corporations through channels enabled by ''Citizens United''."<ref name=":0">{{Cite journal|last1=Klumpp|first1=Tilman|last2=Mialon|first2=Hugo M.|last3=Williams|first3=Michael A.|date=2016|title=The Business of American Democracy: Citizens United, Independent Spending, and Elections|journal=The Journal of Law and Economics|language=en|volume=59|issue=1|pages=1–43|doi=10.1086/685691|s2cid=222330780|issn=0022-2186}}</ref>

==See also==
* [[2010 term opinions of the Supreme Court of the United States]]
* [[End Citizens United]]
* [[Stamp Stampede]]
* [[Issue advocacy ads]]
* ''[[First National Bank of Boston v. Bellotti]]''

==References==
{{Reflist|30em}}

==Further reading==
* Alexander M. "Citizens United and equality forgotten" 35 ''New York University Review of Law & Social Change'' (2011) 499.
* Dawood, Yasmin. "Campaign Finance and American Democracy." ''Annual Review of Political Science'' (2015) [https://ssrn.com/abstract=2528587 Abstract & download]
* Epstein, Richard A. "Citizens United v. FEC: the constitutional right that big corporations should have but do not want" Harvard Journal of Law and Public Policy. 34 (2): 639+.
* Gerken H. "The real problem with Citizens United: Campaign finance, dark money, and shadow parties" 97 ''[[Marquette Law Review]]'' (2014) 903.
* Hansen, Wendy L., Michael S. Rocca, and Brittany Leigh Ortiz. "The effects of Citizens United on corporate spending in the 2012 presidential election." ''Journal of Politics'' 77.2 (2015): 535–545. [https://www.jstor.org/stable/10.1086/680077 in JSTOR]
* Kang, M. "The end of campaign finance law" 98 ''Virginia Law Review'' (2012).
* Post, Robert, ed. ''Citizens Divided: Campaign Finance Reform and the Constitution'' (Harvard University Press, 2014).

==External links==
* {{caselaw source
 |case=''Citizens United v. Federal Election Commission'', {{ussc|558|310|2010|el=no}}
 |cornell =https://www.law.cornell.edu/supct/html/08-205.ZO.html
 |courtlistener =https://www.courtlistener.com/opinion/1741/citizens-united-v-federal-election-comn/
 |findlaw=https://caselaw.findlaw.com/us-supreme-court/08-205.html
 |googlescholar = https://scholar.google.com/scholar_case?case=6233137937069871624
 |justia=https://supreme.justia.com/cases/federal/us/558/08-205/
}}
* [http://www.scotusblog.com/case-files/cases/citizens-united-v-federal-election-commission/ Court documents]
* [https://web.archive.org/web/20170702021217/https://www.supremecourt.gov/oral_arguments/argument_transcripts/08-205%5BReargued%5D.pdf Oral Argument Transcript, PDF] links to one of the two oral arguments.
* [https://www.supremecourt.gov/opinions/09pdf/08-205.pdf Text of Supreme Court decision, PDF]

{{US1stAmendment|speech}}

{{DEFAULTSORT:Citizens United v. Federal Election Commission}}
[[Category:2010 in United States case law]]
[[Category:Corporate personhood]]
[[Category:Federal Election Commission litigation]]
[[Category:Campaign finance in the United States]]
[[Category:United States elections case law]]
[[Category:United States Free Speech Clause case law]]
[[Category:United States Supreme Court cases of the Roberts Court]]
[[Category:United States Supreme Court cases]]
[[Category:United States Supreme Court decisions that overrule a prior Supreme Court decision]]
[[Category:Judicial activism]]
[[Category:Democratic backsliding in the United States]]