Good Corporation, Bad Corporation Corporate Social Corporations and Politics Citizens United

Chapter 11 Corporations and Politics After Citizens United . Montgomery , Figure . Supreme Court decision in Citizens United ru . Federal Elections Committee gave to corporations in election periods , allowing business interests to spend unlimited amounts on US . elections . Do deserve tbe same as it comes to political ?

Corporate Influence on Politics Corporations today exert a considerable ( and occasionally overwhelming ) on global politics . In some countries , the of corporations on government is so great as to give rise to the suspicion that the government is actually controlled by corporations . Even in those countries that strictly limit corporate on political campaigns , the corporate sector can still play an important role in the development of governmental through sophisticated , lobbying . In this chapter we ask , how much of this corporate is acceptable ?

We will also explore the following related questions How can corporate be controlled ?

What is the appropriate level of corporate participation in the drafting of laws and regulations ?

Should corporations be allowed to Corporations and Politics After Citizens Goad , Bad I contribute freely to political campaigns ?

What is the role of foreign and multinational corporations ?

Should they also be allowed to domestic politics ?

Although we will focus on corporate , let us note at the outset that they are not the only source of money in politics wealthy individuals , unions , and other participants in the electoral process also contribute funds and resources to campaigns . In the United States , as in most other industrialized democracies , electoral campaigns have become increasingly expensive despite attempts to limit allowable expenditures . Given the importance of the issue , it is not surprising that a storm of controversy arose over a US Supreme Court ruling in 2010 that government limits on corporate spending in political campaigns violated the First Amendment right to freedom of speech . In the view of an openly dismayed President Barack Obama , the Courts decision in Citizen United ) Federal Elections Commission reversed a century of law to open the for special foreign spend without limit in our The validity of President Obama objection to Citizen United has been hotly contested , and it will provide us with a focal point for our discussion Is it true that corporations have achieved excessive over national politics ?

Are corporations entitled to be treated as persons when it comes to freedom of speech ?

A Basic Distinction Private Public Funding of Campaigns While private election spending in the United States is increasing , the situation around the world is quite diverse . In some countries , expenditures are increasing while elsewhere they are decreasing . A basic distinction in national campaign finance regulations is that some countries allow private support for political campaigns while other countries provide public funds to candidates . Private Finance In the United Kingdom there are no limits on corporate or individual giving in the general election , yet total spending on the 2010 general election was down 26 percent from However , in the United Kingdom , the Prime Minister may call for elections at any time within a maximum period , which shortens the total time available for campaigning and explains the need for funds . National elections tend to be more expensive in the United States because they come along at predictable intervals . In Brazil , it is estimated that billion was spent by parties and candidates in the 2010 presidential election , with nearly 100 percent of total campaign donations coming from corporations . Public Funding In countries such as Norway , government funding accounts for up to 74 percent of political campaigns , and political ads are banned from television and radio . In Canada , candidates are given strict spending limits based on the number of voters in their districts , in order to even the playing field in elections , and private donations ( a maximum of to any party ) are heavily subsidized by public funds paid out through Corporations and Politics After Citizens 148

Good Corporation , Bad Corporation tax credits . Although the price of elections has grown 50 percent in the past decade , spent just 300 million on the 2008 general Campaign Finance in the . US Campaign Finance Law , PACs and Super PACs are two tbat are important in politics . is money , and I can remember second one is . Hanna , campaign manager of President ey successful bid for Presidency in 96 . Concern over the of money in politics began at an early stage in the life of the United States , with Thomas Jefferson stating in 1816 that he feared it would be necessary to crush in its birth the aristocracy of our moneyed corporations , which dare already to our government to a trial of strength and bid to the laws of our Despite Jefferson hopes , the of corporations on politics grew substantially in the latter half of the nineteenth century . The presidential elections of 1896 and 1904 left much of the American populace disgusted and convinced that political in the United States was up for sale . In 1896 , the victor in the presidential election , William McKinley , outspent his competitor , the populist William Jennings Bryan , by a factor of 10 to . In 1904 , the Democratic candidate , Alton Parker , lost the election and complained bitterly afterward that he had been defeated by large insurance companies . Parker challenged the nation to face the reality that corporations were taking over the political process The greatest moral question which now confronts us is shall the trusts and corporations be prevented from contributing money to control or aid in controlling elections ?

Theodore Roosevelt took the accusation seriously and joined his own voice in the call for control of corporate contributions . In a 1905 address to Congress , Roosevelt called for legislation All contributions by corporations to any political committee or for any political purpose should be forbidden by law directors should not be permitted to use holders money for such purposes and , moreover , a prohibition of this kind would be , as far as it went , an effective method of stopping the evils aimed at in corrupt practices acts . Not only should both the National and the several State Legislatures forbid any of a corporation from using the money of the corporation in or about any tion , but they should also forbid such use of money in connection with any legislation save by the employment of counsel in public manner for distinctly legal As a result , Congress passed the 1907 Act , the first US law prohibiting from contributing directly to federal elections . However , it turned out that the law was easy to circumvent . Not only was there no enforcement mechanism or agency , the Act did not prevent corporate contributions to party primaries , and in many districts these were even more determinative than the general election . Moreover , the Act did not prohibit corporate from giving money personally to campaigns ( the executives were then often reimbursed by bonuses from the corporations ) It rapidly became clear that the Act would only be the beginning of a long and tortuous effort to curtail corporate . Corporations and Politics After Citizens

Good Corporation , Bad Corporation After World War II , labor unrest reached a historical high . From , millions of railroad , auto , meatpacking , electric , steel , and coal workers went on strike , protesting falling wages amid rising corporate . Corporate fears of powerful labor unions and the perception among politicians that labor unions had communist leanings convinced Congress to pass the Act ( also known as the Labor Management Relations Act ) in 1947 , which limited workers rights to strike , boycott , and picket . The law also prohibited labor unions from spending money in federal elections and campaigns . As an extension of the Act of 1907 , constrained labor unions to raising money for campaign contributions only through political action committees ( PACs ) It was not until the that PACs were regulated by the federal government . With the passing of the Federal Election Campaign Act ( in 1971 ( and subsequent Amendments in 1974 , 1976 , and 1979 ) the modern campaign system was born , along with an independent body to enforce Federal Election Commission The new law how PACs could operate , set contribution limits , and instituted public for presidential Until 2010 , individuals were limited to contributions to PACs , and were strictly banned from donating . However , as we shall see below , the United case radically altered this landscape , removing all corporate restrictions and giving rise to the Super political action committee that can accept unlimited donations from individuals , corporations , and unions , and engage in unlimited spending . The only restriction on Super PACs is that the donors can not coordinate activities with any candidate or campaign . As we can see below from the satirical commentary by television personality Stephen on the effectiveness of such a bar on coordination , many felt that Super PACs were in reality little more than funding mechanisms under the control of politicians themselves . It seemed that the efforts to control corporate contributions , begun with the Act , had reached a dead end . Corporations and Politics After Citizens

Good Corporation , Bad Corporation ( Figure In 20 , formed a Super PAC , for a Better Tomorrow , it was intended as a satire of existing Super PACs , it was also a way to educate viewers about tbe Citizens United decision . In January 2012 , decided to run for President of tbe United States of Carolina . As was legally required , be passed of bis Super PAC to someone totally to tbe Comedy Central Stewart . Milestones in Campaign Finances ' 1907 Passage of the Act , which banned corporate political contributions to national ' 1925 The Federal Corrupt Practices Act increased disclosure requirements and spending limits on general ' 1971 Passage of the Federal Election Campaign Act ( the campaign ' 1974 Amendments made to the Federal Election Campaign Act limits on , increased disclosure , creation of the Federal Election Commission ( as a regulatory agency , government funding of presidential campaigns . Corporations and Politics After Citizens 151

, Bad ' 1976 Buckley ) The Supreme Court upheld limits on campaign , but held that spending money to elections is protected speech under the First ' 1978 Bank ) Be ' The Supreme Court upheld the rights of corporations to spend money in elections ( ballot initiatives and ) 1990 Austin ) of Commerce The Supreme Court upheld the right of the state of Michigan to prohibit corporations from using money from their corporate treasuries to support or oppose candidates in elections , noting corporate wealth can unfairly ' 2002 Passage of the Bipartisan Campaign Reform Act of 2002 ( which banned corporate funding of issue advocacy ads that mentioned candidates close to an ' 2010 United ) The Supreme Court held that corporate funding of independent political broadcasts in candidate elections can not be limited under the First Amendment , overruling ( 1990 ) The 2012 Presidential Election The 2012 US presidential race was the most expensive in history . According to the Federal Election Commission , approximately billion was spent on the election by , parties , and outside groups . Of that , 933 million came directly from companies , unions , and individuals funneling money into Super PACs enabled by Citizens United . The Center for Public Integrity found that nearly ( approximately 611 million ) went to just ten political consulting firms , who spent 89 percent of the money on negative advertising spots attacking One One Percent According to the Sunlight Foundation , there is a growing dependence on the One cent of the One elite group of the wealthiest Americans , including corporate executives , investors , lobbyists , and lawyers in metropolitan areas who give to multiple , parties , and independent issue groups . Data suggests that , while these ideological donors make up less than percent of the US population , they control about of Americas net worth and contribute up to 25 percent of the money provided to all federal political Corporations and Politics After Citizens 152

Good Corporation , Baal Corporation WHO ARE THE POLITICAL ?

Lu WHO THEYARE LIVE , Executive Lobbyist . ex . I Giving One Percent av One oi Money Dennis in WHO THEY HOW MUCH THEY GAVE and 5275 am aw man min Design and am Processing the sun Courtesy Foundation ( 2013 ) Figure Statistics tbat US . population contributes a major of all American political campaign funding . Case Study Citizens United Federal Elections Commission In early 2010 , the United States Supreme Court shocked much of the nation when it ruled that corporations have the same rights of political free speech as individuals under the Corporations and Politics After Citizens

Good Corporation , Bad Corporation First Amendment to the US Constitution . Citizens United ) Federal Elections Commission was a constitutional law case the Bipartisan Campaign Reform Act ( of 2002 , otherwise known as the campaign law . The barred corporations and unions from running broadcast , cable , or television ads for or against Presidential candidates for thirty days before primary elections , and within 60 days of general elections . In addition , the law required donor disclosure and on all materials not authorized or endorsed by the candidate . The Supreme Court The United States Supreme Court plays a central and occasionally polarizing role in the American democratic system . Created by the Judiciary Act of 1789 , the Supreme Court is the only court prescribed by the Constitution . As the highest court in the land , it remains the functional and symbolic defender of American civil rights and liberties . As the United States court of appeal , the Supreme Court is the ultimate of law in the United States . With the authority to strike down any federal and state law it deems unconstitutional , the Court acts as a check on the power of the executive and legislative branches of government . In theory , the Supreme Court guarantees that changing majority views don subjugate vulnerable minorities or undermine fundamental American values such as freedom of speech . Because it often appears to defend these values in direct opposition to popular opinion , the Supreme Court has been criticized as an antidemocratic institution that fails to take into account progressive social evolution . Indeed , justices are often accused of ideological activism , constitutional fundamentalism , and ignorance of the changing face of the ican public . It can also be argued , however , that the Supreme Court decisions historically have growing national sentiments about constitutional issues more consistently than it has rejected them . Virtually every political and social , gay marriage , tive action , civil rights , immigration , and so before the Supreme Court at some are appointed for life so that , ideally , they will not be swayed by outside political unlike the president or Congress , they do not have to worry about campaigns or approval ratings . The Supreme Court decisions have often had sweeping and profound consequences to society , and they almost always passions on both sides of the political spectrum . The Plaintiff Citizens United , a conservative corporation , wanted to run an cable documentary called Movie , which harshly criticized Hillary Clinton during the Democratic presidential primary in 2008 . The documentary featured interviews with conservative pundits and politicians who claimed that Clinton would be a presidential disaster . The Federal Elections Committee ( blocked the documentary from being cast , designating it as electioneering communication under the . Citizens United brought its case to the United States District Court for the District of Columbia , citing violation of the groups First Amendment rights , but the lower court sided with the . The case was appealed and appeared before the Supreme Court in early 2009 . Corporations and Politics After Citizens 154

Corporation , Bad Corporation I I In 2004 , Michael Moore released a documentary , shortly before the primary elections . The movie was a scathing indictment of George Bush , his administration War on Terror , and the consequences of his first term as dent . Citizens United filed a complaint with the , stating that ads for the were television broadcast communications designed to voters , and therefore violated federal election law . The dismissed the complaint , saying it was clear that , along with its television trailers and website , were purely commercial pursuits . In response , Citizens United decided to start producing its own commercial documentaries . Ar Before the Supreme Court , Citizens United argued that the ( the Act ) only applied to commercial advertisements , not to , documentaries such as Movie . The groups lawyer , Ted , did not even mention the First Amendment , nor did he call for the repeal of any part of federal election law . Taking the opposite position was the deputy solicitor general , who argued that the Clinton documentary was the equivalent of an extended campaign advertisement , recalling the Supreme Court decisions in Austin ) 1990 ) which held that state legislatures may prohibit corporations from using treasury funds on electoral speech , and ) Federal Election ( 2003 ) which validated the spending limitations , stating that express advocacy and its functional equivalent may be treated alike , and that definition of electioneering communication is not facially First Opinion After the case was argued , the Court decided that the did not apply to Movie , and therefore Citizens United could air it unhindered . Chief Justice John drafted an opinion , but it soon became clear that many of the justices didn think it went far enough . The conservative majority felt that the case was a perfect opportunity to broaden the discussion to address whether or not corporate speech should be regulated at all under the Constitution . Roberts withdrew his opinion , and the Court called for the case to be in September , almost a month before the start of the fall term and two months before the 2010 midterm election . The justices directed the parties to supplemental briefs dressing the question of whether the Court should overrule Austin ) and parts of ) which would amount to eliminating decades of restrictions on corporate electoral spending . Second Opinion The Citizens United case was on September . By a vote , the conservative majority held that the First Amendment to the United States Constitution prohibits the government from imposing any limits on political spending by corporations , associations , and unions . Justice Anthony Kennedy wrote the majority opinion , which he summarized from the bench in this way Political speech is indispensable to decision Corporations and Politics After Citizens 155

Good Corporation , Bad Corporation making in a democracy and this is no less true because the speech comes from a corporation rather than an Justice Kennedy was joined by Chief Justice John Roberts and Justices , Samuel , and Clarence Thomas . To the conservative judges , the ruling was a tion of the power of free speech because of United , the First Amendment could now be applied universally and without prejudice . Dissent Justice John Paul Stevens wrote a highly critical dissent , arguing that Justice Kennedy opinion constituted a rejection of the common sense of the American people , who have recognized a need to prevent corporations from undermining since the Stevens believed that the limits Congress had for years imposed on corporate spending were necessary to curb political corruption by the wealthiest cans , who would inevitably , and the vast majority of Americans . Stevens also argued that corporations are not people in the real do not have consciences , feelings , beliefs , or therefore are not true members of society , or We the People , by whom and for whom the Constitution was Justice Stevens was joined in his dissent by Justices Ruth , Stephen , and Sonia . These liberal justices recognized that the decision would open the for spending in electoral campaigns , making it exceedingly to maintain that independent expenditures by corporations do not give rise to corruption or the appearance of 15 Corporate Personhood Widespread public criticism of the Citizen United decision has not diminished with time , particularly from liberal or progressive voters and pundits . Protesters , lawmakers , and organizations such as Move to Amend have called for a constitutional amendment to turn the ruling . Across the country , a number of public demonstrations were held where participants waved signs reading , Corporations Are Not Despite the widespread outrage , the reality is that corporations have had many of the same rights as individuals for a very long time . Corporate refers to the legal concept that allows organizations of people , as individuals acting collectively , to be both protected by the Constitution and subject to the same laws as citizens . The word corporation derives from the Latin , corpus , meaning body , and is as a body of people acting jointly , by law as acting as an The Romans first devised corporate personhood as a way for cities and churches to legally organize for the purposes of joint land ownership , taxation , and institutional . Creating a legal or artificial person made it unnecessary to develop separate laws enabling large groups of people to do the same things as individuals for instance , make contracts , own property , pay taxes , borrow money , enter into law suits , and be protected from persecution . Since at least 1819 , in College 72 . Woodward , the Supreme Court has recognized corporations as having the same rights as natural persons for the purpose of contracts . Since then , the Supreme Court has given corporations increasingly more rights traditionally reserved for natural people Fourteenth Amendment rights of equal protection Corporations and Politics After Citizens 156

Good Corporation , Bad Corporation ( Consolidated Silver Mining ) Pennsylvania , 1888 ) Fifth Amendment of due process ( Noble Union River Logging , 1893 ) Fourth Amendment search and seizure protection ( Hale ) 1906 ) immunity ( Fong Foo ) United States , 1962 ) First Amendment protection ( American Press Company , 1936 ) Seventh Amendment rights to trial by jury ( Ross ) 1970 ) the right to spend money in elections ( First National Bank of Boston ) 1978 ) and the right to spend in campaigns as a form of speech ( Buckley ) 1976 ) Amending the Constitution to Overrule Citizens United Move to Amend , a coalition of political interest organizations , lead the campaign for a Constitutional amendment that would overturn the Supreme Court decision in Citizens United . clearly states We , the People of the United States of America , reject the US Supreme Court ruling in Citizens United and other related cases , and move to amend our Constitution to establish that money is not speech , and that human beings , not corporations , are persons entitled to constitutional Consequences Specialists in campaign law predict that the Supreme Court ruling will shape the US electoral process for years to come . The matter is far from settled , however , as there is a growing movement of nonpartisan municipal , county , and state bodies calling for a constitutional amendment to overturn the decision . Citizens United legacy is far from over . Topic for Debate Overrule Citizens United In this debate section , you will be asked to assume the role of a college student at a campus in New York State . The Congressional representative who has been elected from your university district has introduced a bill in Congress that would authorize a constitutional amendment to overturn Citizens United . The university newspaper has sponsored a public debate so that the it can determine what position to the newspaper endorse ( or not ) the proposed amendment ?

You have been invited to be a part of one of the two debate teams that will address the issue at a public forum . You are expected to base your arguments to some extent on the statements and publications of legal and public policy experts . Affirmative The university newspaper should endorse a constitutional amendment to overturn Citizens United . Possible Arguments ' Corporations are not people , and should not have the same rights as ' The Supreme Court erred with its decision in Citizens United , due to judicial activism . Corporations and Politics After Citizens 15

Good Corporation , Bod Corporation ' Electoral issues should be decided by elected and not by the Supreme ' Corporate money inherently leads to political corruption and secret ' Wealthy Americans by and large represent the corporate interests of America and should not drown out the voices of those with less power and money Negative The university newspaper should oppose a constitutional amendment to overturn United . Possible Arguments ' American democracy relies on freedom of speech , which should therefore be by everyone , regardless of their legal ' Corporate money in elections increases political competition and awareness of ' Americans can decide for themselves whether or not to elect a candidate ads don make a difference either ' Corporations advocate for their employees , customers , and communities , and lation will only constrain this ability ' Corporations are fundamental to American economic progress and should be lowed to the political process to maintain their positive contributions to society . Readings Supreme Court Opinion and Pleadings The Supreme Court majority opinion , the various dissenting and concurring opinions , and the parties briefs , may be accessed on the Internet at the following links The arguments and decision can be found at United ) Federal Election The Project at UT College of Law . Last updated August 08 205 . The briefs and amicus briefs can be found at Citizen United ) Federal Election . June A video can be found at The Story of Citizens United ) 2011 ) YouTube video , Posted by on February 25 , Corporations and Politics After Citizens 158

Good Corporation , Bad Corporation Why Super PACs Are Good for Democracy Super PACs Get Government out of the Business of Regulating Speech Smith , Bradley A . Why Super PACs Are Good for Democracy Super PACs Get Government out of the Business of Regulating US . News and World Report . February . The New York Times Disingenuous Campaign against Citizens United , Wendy . The New York Times Disingenuous Campaign against Atlantic . February . paper it promoting misconception ruling allowed for unlimited campaign from individuals . It didn . Like Fox News , the New York Time has a First Amendment right to spread formation about important public issues , and it is exercising that right in its campaign against the United ruling . In news stories , as well as columns , it has repeatedly United , explicitly or implicitly blaming it for allowing unlimited super PAC contributions from individuals . In fact , Citizen United enabled and unions to use general treasury funds for independent political expenditures it did not expand or address the longstanding , individual rights of the rich to support independent groups . And , as recent reports have made clear , individual donors , not rations , are the primary funders of super PACs . When I focused on the inaccurate reference to Citizens United in a story about Sheldon , I assumed it was a more or less honest if negligent mistake . And I still don blame columnists for misconceptions about a complicated case that are gleaned from news stories and apparently shared by their editors . But mistakes about United are beginning to look more like propaganda , because even after being alerted to its , the Time has continued to repeat them . First Amendment lawyer Floyd wrote to the editors pointing out of United in two news stories , but instead of publishing corrections , the Time published letter on the editorial page , effectively framing a factual error as a difference of opinion . As these examples suggest , reforms dating back decades have an , overreaching web of laws and regulations that are easily abused , misunderstood , or intentionally complexities of campaign finance law ( and provisions governing independent groups ) also create incentives to oversimplify the problems caused by the regime by naming Citizen United as the root of all evils . This helps advance what appears to be a simple United with a free speech for people constitutional amendment declaring that corporations aren people . Putting aside the dangers of this approach , it wouldnt solve the problem of super PACs The billionaires funding them may lack personal appeal but they are , after all , people , whose expenditures were not at issue in United . When the press promotes false Corporations and Politics After Citizens

Good Corporation , Bad Corporation understandings of Citizen United and the problems of campaign , it paves the way for false solutions . Its worth noting that the Time is not alone among proponents of reform in Citizen United ( although it seems to have taken the lead . The New York Time , the Wa Po , and regularly and routinely misstate the meaning and impact of the Supreme Court Citizen United decision on campaign rules , Steve Brill recently observed , citing a post by Dan . Brill recommends confronting reporters and commentators with their frequent . Former Executive Director Ira Glasser has gamely tried engaging New York Time Public Editor Arthur in an effort to stop misleading readers you confused yet ?

What does the Time believe or want you to believe about Citizen United ?

Whatever . The Citizens United Catastrophe , The Citizens United Wa Po February , Experts Assess Impact of Citizens United Professor Suggests Constitutional Amendment Stating Corporations Are Not People , Jill . Experts Assess Impact of Citizens Harvard ' February , 20 . Few recent Supreme Court cases have received as much drawn as much Citizen United ) Federal Election ion . In a decision , the court ruled that the First Amendment prohibits government from placing limits on independent spending for political purposes by corporations and unions . To proponents of campaign reform , Citizen United had the detrimental effect of an campaign system with corporate . At an event sponsored by the Harvard Law School ( American Constitution Society on Tuesday , Professor Lawrence , author of Republic Lo , and Jeff Clements , author of Corporation Are Not People , reviewed the impact that Citizen United has had on the political process . Clements said that the court decision exacerbates two problems that the American political and electoral system had already been large amount of campaign spending and the growing of corporate power on the political process . Clements said that both problems need to be in order to restore democracy but that , rather than addressing these problems , the Citizen United decision instead requires that the American people fundamentally reframe their notion of corporations . We need to look at what Citizen United really asks us to do , which is to accept a lot . The court asks us to pretend that corporations are not massive creations of state , federal , and foreign laws . It asks us to pretend that they re just like people , that they have voices , and that we re not allowed to make separate rules for them , he said . Although some legal observers regard the decision as simply a bad day on the court , Clements said that Citizen United actually represents the culmination of a steady creation of a corporate rights doctrine that is radical in terms of American jurisprudence . He Corporations and Politics After Citizens

Goad Corporation , Bad Corporation a history of the idea of corporate personhood and corporate speech , which began only in the under Chief Justice William . added that the system that has resulted is one in which elected must spend 30 to 50 percent of their time fundraising , and thus make decisions based not on what is best for their constituents , but on what their super PACs and other major donors want to see . We have a corrupt government , yet one that is perfectly legal , said . We ve allowed a government to evolve in which Congress isn dependent on people alone , but is instead increasingly dependent on its funders . As you bend to the green , that corrupts the As a result , he said , members of Congress develop a sixth sense as to what will raise money , which has led them to bend government away from what the people want ment to do and toward what their funders want government to do . To the problem , we need to produce a system where the funders and the people are one and the solution , said , is a approach that includes a constitutional amendment explicitly stating that corporations are not people , as well as a movement to publicly fund elections and provide Congress with the power to limit independent expenditures . Synthesis Questions . Do corporations have too much on American politics ?

Support your arguments with examples of excessive or lack of excessive . Why do so many people find it repugnant to treat corporations as persons ?

Is this disfavor justifiable ?

Remarks by the President in State of the Union Address , January 27 , 2010 , accessed December , 2014 , Political Party Spending at Elections , lhe Electoral Commission , accessed October 25 , 2013 , Anna , Election Costs Have Skyrocketed in Past Decade , He Globe and Mail , August 23 , 2012 , Jefferson , Thomas . The Jeffersonian Cyclopedia . Funk and Company New York and London . Nichols , John . Fears Lawless Court Ruling on Corporate He Nation . 12 , 2010 . Roosevelt , Theodore . Fifth Annual Message . The American Presidency Project . The and the Federal Campaign Finance Law , Federal Election Commission , last updated January 2013 , Corporations and Politics After Citizens 161

, Baal . Victor . Campaign Finance Reform Historical Timeline , Connecticut Network , accessed October 25 , 2013 , Austin Michigan Chamber of Commerce , 494 US . 652 ( 1990 ) Supreme Court . March 27 , 10 . Court Opened Door to 933 Million in New Election Spending , The Center for Public , 20 , 2013 , 11 . Lee , The Political One Percent of the One Percent , Sunlight dation , December 13 , 2011 , 12 . Elena , United , Appellant ru . Supplemental the Appellee , The Supreme Court of the United States , no . 2009 , 13 . United , Appellant ru . ion , The Project at College of Law , last updated August 25 , 2014 , 205 . 14 . Citizens United Federal Election Commission , 558 310 ( 2010 ) 15 . Mike Sacks , Citizens United Foes John McCain , Sheldon Take Argument to Supreme Court , Post , May 18 , 2012 , 16 . Corporation . Dictionary . 267 . Allied Chambers Publishers New Delhi . 2004 . 17 . Timeline Rights and Powers , accessed October 25 , 2013 , 18 . Timeline Rights and Powers . Corporations and Politics After Citizens