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Citizens United v. FEC

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Citizens United v. Federal Election Commission
Supreme Court of the United States
Argued March 24, 2009
Reargued September 9, 2009
Decided January 21, 2010
Full case nameCitizens United, Appellant v. Federal Election Commission
Docket no.08-205
Case history
Priordefendant granted summary judgement 530 F. Supp. 2d 274 (D.C. 2008),[1] certiorari granted U.S.
Questions presented
Whether federal campaign finance laws apply to a critical film about Senator Hillary Clinton intended to be shown in theaters and on-demand to cable subscribers.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens · Antonin Scalia
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Case opinions
MajorityKennedy, joined by Roberts, Scalia, Alito; Thomas (all but Part IV); Stevens, Ginsburg, Breyer, Sotomayor (only as to Part IV)
ConcurrenceRoberts, joined by Alito
ConcurrenceScalia, joined by Alito; Thomas (in part)
Concur/dissentStevens, joined by Ginsburg, Breyer, Sotomayor
Concur/dissentThomas

Citizens United v. Federal Election Commission, 558 U.S. ___ (2010) is a landmark 5-to-4 decision by the United States Supreme Court that corporate funding of independent political broadcasts in candidate elections cannot be limited, because doing so would be in noncompliance with the First Amendment. The decision resulted from the non-profit corporation Citizens United's case before the court regarding whether the group's film critical of a political candidate could be defined as a campaign advertisement under the 2002 Bipartisan Campaign Reform Act, commonly known as the McCain-Feingold Act.[2]

The decision reached the Supreme Court on appeal from a 2008 decision by the United States District Court for the District of Columbia, which sided with the Federal Election Commission (FEC), holding that under the McCain-Feingold Act the film Hillary: The Movie could not be shown on television right before the 2008 Democratic primaries.[citation needed]

The Court's decision struck down a provision of the McCain-Feingold Act that banned for-profit and not-for-profit corporations and unions from broadcasting “electioneering communications” in the 30 days before a presidential primary and in the 60 days before the general elections.[2] The decision completely overruled Austin v. Michigan Chamber of Commerce (1990) and partially overruled McConnell v. Federal Election Commission (2003).[3] The decision upheld the requirements for disclaimer and disclosure by sponsors of advertisements, and the ban on direct contributions from corporations or unions to candidates, in part IV.[4]

Background

Citizens United, a conservative nonprofit 501(c)(4) organization, sought to run television commercials promoting its film Hillary: The Movie, a documentary critical of then-Senator Hillary Clinton, and to show the movie on DirecTV.[5] The Bipartisan Campaign Reform Act of 2002 (BCRA)(AKA McCain-Feingold), 2 U.S.C. § 441b, prohibited corporations and unions from using their general treasury funds to make independent expenditures for speech that is an "electioneering communication" or for speech that expressly advocates the election or defeat of a candidate. In January 2008, the United States District Court for the District of Columbia ruled that the commercials violated provisions in the Bipartisan Campaign Reform Act of 2002 (McCain-Feingold) restricting "electioneering communications" 30 days before primaries. The Court found that the film had no other purpose than to discredit Clinton; Citizens United argued that the film was fact-based and nonpartisan.[6]

The Supreme Court docketed this case on August 18, 2008,[7] and heard oral arguments on March 24, 2009.[5][8][9] A decision was expected sometime in the early summer months of 2009.[10]

However, on June 29, 2009, the Supreme Court issued an order directing the parties to reargue the case on September 9 after issuing briefs on larger issues.[11] One issue in particular that likely contributed to the Court's desire to have the case reargued was the statement by then-Deputy Solicitor General Malcolm L. Stewart, representing the FEC, that the government would have the power to ban books, if those books constituted express advocacy and were published by a corporation or union. At oral argument, Citizens United was to address the following question: "For the disposition of this case, should the Court overrule either or both Austin v. Michigan Chamber of Commerce and the part of McConnell v. FEC which addresses the facial validity of Section 203 of the Bipartisan Campaign Reform Act of 2002?"[12]

The case was the first to be heard by Justice Sotomayor and the first case to be argued in the Supreme Court by Solicitor General Elena Kagan. Also arguing before the Court were former Bush solicitor general Ted Olson, First Amendment lawyer Floyd Abrams, and former Clinton solicitor general Seth Waxman.[13] Legal scholar Erwin Chemerinsky called it "one of the most important First Amendment cases in years."[14]

Decision

The majority opinion, which was delivered by Justice Kennedy, found that §441b's restrictions on expenditures were invalid and could not be applied to spending like that in the film in question. 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." He also noted that since there was no way to distinguish between media and other corporations, these restrictions would allow Congress to suppress political speech in newspapers, books, television and blogs.[2] The Court overruled Austin v. Michigan Chamber of Commerce which had previously held that a Michigan Campaign Finance act that prohibited corporations from using treasury money to support or oppose candidates in elections did not violate the First and Fourteenth Amendments. The Court also overruled the part of McConnell v. Federal Election Commission that upheld BCRA §203's extension of §441b's restrictions on independent corporate expenditures.

The Court found that BCRA §§201 and 311 were valid as applied to the ads for Hillary and to the movie itself.

Roberts concurrence

Chief Justice Roberts, with whom Justice Alito joined, wrote separately "to address the important principles of judicial restraint and stare decisis implicated in this case."

Scalia concurrence

Stevens concurrence/dissent

Justice Stevens, with whom Justice Ginsburg, Justice Breyer, and Justice Sotomayor joined, concurred in part, in the Court's decision to sustain BCRA's disclosure provisions and joining Part IV of its opinion, and dissented with the principal holding of the majority opinion. The dissent held that the Court's 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." The dissent also argued that The Court declaring §203 of BCRA facially unconstitutional was a ruling on a question not brought before them by the litigants, and so they "changed the case to give themselves an opportunity to change the law." Stevens concluded his dissent with:

"At bottom, the Court's opinion is thus a rejection of the common sense of the American people, who have recognized a need to prevent corporations from undermining self government since the founding, and who have fought against the distinctive corrupting potential of corporate electioneering since the days of Theodore Roosevelt. It is a strange time to repudiate that common sense. While American democracy is imperfect, few outside the majority of this Court would have thought its flaws included a dearth of corporate money in politics."

Thomas concurrence/dissent

Justice Thomas wrote a separate opinion concurring in part and dissenting in part. Thomas concurred in the portions of the decision striking down Austin and portions of McConnell; however, Thomas would have gone further and invalidated the reporting requirements of BCRA §§201 and 311 as well, rather than allowing them to be challenged only on a case-specific basis.

Thomas's primary argument is that anonymous free speech is protected, for which he cites McIntyre v. Ohio Elections Commission, 514 U.S. 334, 348 (1995). He points out that making contributor lists public makes the contributors vulnerable to retaliation, and cites instances of retaliation – "death threats, ruined careers, damaged or defaced property, or pre-emptive and threatening warning letters" – against contributors to political groups on both sides of a then recent California voter initiative. Thomas also expresses concern that such retaliation could extend to retaliation by elected officials.

Thomas does not consider "as applied exceptions" to be sufficient to protect against the threat of retaliation, and concludes that BCRA §§201 and 311 should be struck down to protect the anonymity of contributors to organizations exercising free speech.

Reactions

There was a wide range of reactions to Citizens United v. FEC from politicians, advocacy groups, academics, attorneys and journalists. In general conservatives and libertarians praised the ruling as preservation of the First Amendment and freedom of speech and liberals and campaign finance reformers criticized it as greatly expanding the the role of corporate money in politics.[15]

Support

Politicians

Senate Republican leader Mitch McConnell, who attended the announcement of the ruling, said the court "struck a blow for the First Amendment."[16]

Capital University Law School professor Bradley A. Smith, a former chair of the Federal Election Commission, wrote that the major opponents of political free speech are "incumbent politicians, shocked by the apparent tectonic shift in politics of late" 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.[17] Campaign finance expert Jan Baran, a member of the Commission on Federal Ethics Law Reform agreed, writing 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."[15] Ed Rollins opined that the decision adds transparency to the election process and will make it more competitive.[18]

Advocacy groups

Citizens United, the group filing the lawsuit 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."[19] During litigation Citizens United had support from the United States Chamber of Commerce and the National Rifle Association.[16]

Campaign finance attorney Cleta Mitchell, who had filed a friend-of-the-court brief on behalf of two advocacy organizations opposing the ban, wrote that "The Supreme Court has correctly eliminated a constitutionally flawed system that allowed media corporations (e.g., The Washington Post Co.) 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."[20]

Heritage Foundation fellow Hans A. von Spakovsky, a former Republican 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."[21]

Cato Institute researchers John Samples and Ilya Shapiro wrote that restrictions on advertising were based on the idea “that corporations had so much money that their spending would create vast inequalities in speech that would undermine democracy.” However, “to make campaign spending equal or nearly so, the government would have to force some people or groups to spend less than they wished. And equality of speech is inherently contrary to protecting speech from government restraint, which is ultimately the heart of American conceptions of free speech.”[22]

Academics and attorneys

Attorney Kenneth Gross, former associate general counsel of the Federal Election Commission, wrote that corporations relied more on the development of long-term relationships, political action committees and personal contributions, which were not affected by the decision. He held that while trade associations might seek to raise funds and support candidates, corporations which have “signed on to transparency agreements regarding political spending” may not be eager to give.[20]

The New York Times asked seven academics to opine on how corporate money will reshape politics as a result of the court's decision.[23] Three of these wrote that the effects would be minimal or positive: University of Miami School of Business assistant professor of economics Christopher Cotton wrote that “There may be very little difference between seeing eight ads or seeing nine ads (compared to seeing one ad or two). 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.[23] University of California professor of law Eugene Volokh held 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.”[23] Joel Gora, a professor at Brooklyn Law School who had previously argued the case of Buckley v. Valeo on behalf of the American Civil Liberties Union, said that the decision represented "a great day for the First Amendment" writing that the Court had "dismantled the First Amendment 'caste system' in election speech."

Journalists

The Editorial Board of the San Antonio Express-News criticized McCain-Feingold's exception for media corporations to its 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.”[24]

Anthony Dick in The National Review countered a number of arguments against the decision, writing "is there something uniquely harmful and/or unworthy of protection about political messages that come from corporations and unions, as opposed to, say, rich individuals, persuasive writers, or charismatic demagogues?" He noted that “a recent Gallup poll shows that a majority of the public actually agrees with the Court that corporations and unions should be treated just like individuals in terms of their political-expenditure rights."[25] According to Jordan Fabian, a Gallup poll taken in October 2009 and released soon after the decision showed 57 percent of those surveyed agreed that contributions to political candidates is a form of free speech and 55 percent agreed that the same rules should apply to individuals, corporations and unions. Sixty-four percent of Democrats and Republicans believed campaign donations are a form of free speech.[26]

Chicago Tribune editorial board member Steve Chapman wrote "If corporate advocacy may be forbidden as it was under the law in question, it's not just Exxon Mobil and Citigroup that are rendered mute. Nonprofit corporations set up merely to advance goals shared by citizens, such as the American Civil Liberties Union and the National Rifle Association, also have to put a sock in it. So much for the First Amendment goal of fostering debate about public policy."[27]

Criticism

Politicians and political parties

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." [28] Obama later elaborated in his weekly radio address saying, "this ruling strikes at our democracy itself" and "I can't think of anything more devastating to the public interest".[29] On 2010-01-27, Obama further condemned the decision during the 2010 State of the Union Address.

Democratic senator Russ Feingold and co-crafter of the 2002 Bipartisan Campaign Reform Act 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."[30] Rep. Alan Grayson stated that it was "the worst Supreme Court decision since the Dred Scott case" and accused the court of opening the door to political bribery and corruption.[31] Democratic congresswoman Donna Edwards, along with constitutional law professor and Democrat Jamie Raskin have advocated petitions to reverse the decision by means of constitutional amendment.[32] Rep. Leonard Boswell has formally introduced legislation to amend the constitution, and is currently seeking co-sponsors.[33]

Republican presidential candidate and Senator John McCain, co-crafter of the 2002 Bipartisan Campaign Reform Act, 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".[34] 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."[30] He pointed out that "Justice Rehnquist and Justice O'Connor, who had taken a different position on this issue, both had significant political experience, while Justices Roberts, Alito and Scalia have none."[34] Republican Senator Olympia Snowe opined that "Today's decision was a serious disservice to our country."[35]

Sanda Everette, co-chair of the Green Party, stated that "The ruling especially hurts the ability of parties that don't accept corporate contributions, like the Green Party, to compete." Rich Whitney stated "In a transparently political decision, a majority of the US Supreme Court overturned its own recent precedent and paid tribute to the giant corporate interests that already wield tremendous power over our political process and political speech." David Cobb stated "The Court has literally legalized corporate bribery of our elected officials." Jody Grage, treasurer of the Green Party, stated "The decision will cement the Democratic and Republican parties' status as subsidiaries of Wall Street, oil companies, defense contractors, insurance firms, media conglomerates, and other top corporations. It cancels the idea that candidates run for public office to serve the public interest. The ruling will help block government measures to curb global warming, regulation of financial firms, health care reform, consumer rights, and all other protections for 'We the People' against corporate power." Farheen Hakeem, co-chair of the Green Party, commented "Restoring democracy and the idea that constitutional rights should only apply to humans will now require a citizens' effort as strong as the Civil Rights Movement."[36]

Ralph Nader, a lawyer and advocate of individual rights, who took the third place in three presidential elections, condemned the ruling,[37] 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." He called for shareholder resolutions asking company directors to pledge not to use company money to favor or oppose electoral candidates.[38] Pat Choate, Reform Party candidate stated, "The court has, in effect, legalized foreign governments and foreign corporations to participate in our electoral politics."[39]

Advocacy groups

The American Civil Liberties Union announced that the ruling has prompted reconsideration of its position on campaign finance limits.[40]

In response to the court's decision, two ongovernmental campaigns have emerged to petition for an amendment to the United States Constitution.[36] Organizations advocating the campaigns include Voter Action, Public Citizen, the Center for Corporate Policy, and the American Independent Business Alliance.[41]

Organization for Security and Co-operation in Europe

Ambassador Janez Lenarčič, speaking for the OSCE's election body, which has overseen over 150 elections, stated that the ruling may adversely affect the organization's two commitments of "giving voters a genuine choice and giving candidates a fair chance" in that "it threatens to further marginalize candidates without strong financial backing or extensive personal resources, thereby in effect narrowing the political arena."[42]

Academics and attorneys

The constitutional law scholar Laurence H. Tribe wrote that the decision "marks a major upheaval in First Amendment law and signals the end of whatever legitimate claim could otherwise have been made by the Roberts Court to an incremental and minimalist approach to constitutional adjudication, to a modest view of the judicial role vis-à-vis the political branches, or to a genuine concern with adherence to precedent" and pointed out that "Talking about 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."[43]

Former supreme court Justice Sandra Day O’Connor criticized the decision only obliquely, but warned that “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.”[44]

Journalists

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."[45] Jonathan Alter called it the "most serious threat to American democracy in a generation."[46]

Some journalists and politicians reacted strongly to the decision with online media journal Veterans Today calling for the "immediate arrest" of the justices voting in the majority for treason.[47] Keith Olbermann of MSNBC said that with this decision "within ten years every politician in this country will be a prostitute" and compared it to the case Dred Scott v. Sanford.[48]

Many critics of the ruling based their responses on misrepresentations of the ruling. For instance, Jonathan Alter stated that "If Goldman Sachs wants to pay the entire cost of every congressional campaign in the U.S., the law of the land now allows it." However, the ruling only affects the funding of independent advertisements; restrictions on other aspects of campaign financing, such as paying travel expenses, would not affected by the ruling.

Effects

The New York Times reported that 24 states with laws prohibiting independent expenditures by unions and corporations will have to change their campaign finance laws because of the ruling. It also will affect pending trials under those laws.[49]

Dick Durbin has proposed that candidates who sign up small donors receive $90,000 USD in public money. Further, laws that govern corporate governance can be amended to assure that shareholders vote on political expenditures as is the case in the United Kingdom.[46]

See also

References

  1. ^ Only the denial of injunction to Citizens United was reported.
  2. ^ a b c Liptak, Adam (2010-01-21). "Justices, 5-4, Reject Corporate Spending Limit". New York Times.
  3. ^ Hasen, Richard (2010-01-21). "Money Grubbers: The Supreme Court kills campaign finance reform". Slate.
  4. ^ Carney, Eliza. "Court Unlikely To Stop With Citizens United". National Journal Online. Retrieved 2010-01-21.
  5. ^ a b Barnes, Robert (2009-03-15). "'Hillary: The Movie' to Get Supreme Court Screening". The Washington Post. Retrieved 2009-03-22.
  6. ^ Memorandum Opinion, Citizens United v. Federal Elections Commission. U.S. District Court for the District of Columbia: January 15, 2008.
  7. ^ Docket for 08-205. U.S. Supreme Court
  8. ^ Ross, Lee (2009-03-18). "March 24: Hillary Clinton Film Challenged". Fox News. Retrieved 2009-03-22.
  9. ^ Holland, Jesse (2009-03-21). "Now showing at Supreme Court: 'Hillary: The Movie'". Associated Press. Retrieved 2009-03-22.
  10. ^ Liptak, Adam (2009-03-25). "Justices Consider Interplay Between First Amendment and Campaign Finance Laws". The New York Times. p. 2. Retrieved 2009-05-09.
  11. ^ Barnes, Robert (2009-06-30). "Justices to Review Campaign Finance Law Constraints". The Washington Post.
  12. ^ "Anti-Hillary dispute to be re-heard". Associated Press. 2009-06-29. Retrieved 2009-06-29.
  13. ^ "Hillary: The Oral Argument". The Washington Post.
  14. ^ Liptak, Adam (August 6, 2009). "Sotomayor Faces Heavy Workload of Complex Cases". The New York Times.
  15. ^ a b Jan Witold Baran, Stampede Toward Democracy, New York Times, January 25, 2010.
  16. ^ a b Greg Stohr, Court Voids Campaign Spending Curbs, MSNBC, January 24, 2010.
  17. ^ Bradley A. Smith, The Citizens United Fallout, Democrats plan to redouble their efforts to stifle corporate free speech, City Journal, January 25, 2010.
  18. ^ Ed Rollins (2010-01-22). "Another shock to the Washington system". CNN. {{cite web}}: Unknown parameter |access date= ignored (|access-date= suggested) (help)
  19. ^ "Statement from David N. Bossie". Citizens United Blog<!. 2010-01-21. Retrieved 2010-01-22.
  20. ^ a b Who is helped, or hurt, by the Citizens United decision?, Washington Post, January 24, 2010; A11.
  21. ^ Stephen Dinan, Divided court strikes down campaign money restrictions, Washington Times, January 21, 2010.
  22. ^ John Samples and Ilya Shapiro, Free Speech for All, Cato Institute, January 21, 2010.
  23. ^ a b c "How Corporate Money Will Reshape Politics: Restoring Free Speech in Elections". The New York Times. 2010-01-21. Retrieved 2010-01-21.
  24. ^ "High court ruling protects speech". San Antonio Express-News Editorial Board. Hearst Newspapers. 2010-01-26. Retrieved 2010-01-26.
  25. ^ Dick, Anthony (2010-01-25). "Defending Citizens United". The National Review.
  26. ^ Fabian, Jordan (2010-01-23). "Poll: Public agrees with principles of campaign finance decision". Blog Briefing Room. The Hill,. Retrieved 2010-01-24.{{cite web}}: CS1 maint: extra punctuation (link)
  27. ^ Chapman, Steve (2010-01-24). "Free speech, even for corporations". Opinion. Chicago Tribune. Retrieved 2010-01-24.
  28. ^ "Obama Criticizes Campaign Finance Ruling". CNN Political Ticker. Turner Broadcasting System, Inc. 2010-01-20. Retrieved 2010-01-22.
  29. ^ Superville, Darlene (2010-01-23). "President Blasts Supreme Court Over Citizens United Decision". Huffington Post. Retrieved 2010-01-23.
  30. ^ a b Hunt, Kasie (2010-01-21). "John McCain, Russ Feingold diverge on court ruling". Politico.
  31. ^ Baumann, Nick (2010-01-22). "Grayson: Court's Campaign Finance Decision "Worst Since Dred Scott"". Mother Jones. Mother Jones and the Foundation for National Progress. Retrieved 2010-01-26.
  32. ^ "Group Calls For Constitutional Amendment to Overturn High Court's Campaign Finance Ruling". The Public Record. 2010-01-21. Retrieved 2010-01-26. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)
  33. ^ Hancock, Jason (2010-01-21). "Boswell pushes constitutional amendment to overturn SCOTUS ruling". The Iowa Independent. Retrieved 2010-01-26. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)
  34. ^ a b Amick, John (2010-01-24). "McCain skeptical Supreme Court decision can be countered". The Washington Post.
  35. ^ "Snowe troubled by U.S. Supreme Court ruling to remove limits on corporate and union spending in political campaigns" (Press release). Retrieved 2010-01-26. {{cite press release}}: Cite has empty unknown parameter: |coauthors= (help)
  36. ^ a b "Greens: The Supreme Court's Citizens United ruling will make the Democratic and Republican parties into subsidiaries of top corporations" (Press release). Green Party of the United States. 2010-01-25. Retrieved 2010-01-26.
  37. ^ Ralph Nader Time to Reign in Out-of-Control Corporate Influences on Our Democracy
  38. ^ Ralph Nader, CounterPunch, 22 January 2010, The Supremes Bow to King Corporation
  39. ^ "Decision May Mean More Foreign Cash". Politico. 2010-01-21. Retrieved 2010-01-22.
  40. ^ Goldstein, Joseph (2010-01-24). "ACLU May Reverse Course On Campaign Finance Limits After Supreme Court Ruling". The New York Sun. http://www.nysun.com/national/aclu-may-reverse-course-on-campaign-finance/86899/. Retrieved 2010-01-26. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help); External link in |publisher= (help)
  41. ^ "What did the Supreme Court just do to our democracy? / freespeechforpeople.org". Retrieved 2010-01-26.
  42. ^ "Head of OSCE election body concerned about U.S. Supreme Court ruling on election spending" (Press release). Warsaw. 2010-01-22. Retrieved 2010-01-26. {{cite press release}}: Cite has empty unknown parameter: |coauthors= (help)
  43. ^ Tribe, Laurence (2010-01-24). "What Should Congress Do About Citizens United? An analysis of the ruling and a possible legislative response". SCOTUSblog.
  44. ^ Liptak, Adam (2010-01-26). "O'Connor Mildly Criticizes Court's Campaign Finance Decision". The Caucus Blog. The New York Times Company.
  45. ^ Kirkpatrick, David (2010-01-22). "Lobbiests Get Potent Weapon in Campaign Financing". New York Times. Retrieved 2010-01-27.
  46. ^ a b Alter, Jonathan (2010-02-01). "High Court Hypocrisy: Dick Durbin's got a good idea". Newsweek. Newsweek, Inc. Retrieved 2010-01-27. {{cite journal}}: Cite has empty unknown parameter: |coauthors= (help)
  47. ^ "Call for Immediate Arrest of Five Supreme Court Justices for Treason". veteranstoday.com<!. 2010-01-22. Retrieved 2010-01-22.
  48. ^ "U.S. Government for Sale". MSNBC. 2010-01-21. Retrieved 2010-01-22.
  49. ^ Urbina, Ian (January 22, 2010). "24 States' Laws Open to Attack After Campaign Finance Ruling". The New York Times. Retrieved 23 January 2010.

External links

Retrieved from "https://en.wikipedia.org/w/index.php?title=Citizens_United_v._FEC&oldid=340660760"