The Legal Framework -- Before and After:

Buckley v. Valeo (1976) set the original rules:

• Spending money to express political views is protected speech
• The government CAN limit direct contributions to candidates (to prevent corruption)
• The government CANNOT limit independent expenditures (spending that isn't coordinated with a campaign)

Citizens United extended Buckley's logic:

1. If independent spending is protected for individuals (Buckley), it must be protected for corporations too (Citizens United)
2. The "anti-distortion" rationale -- preventing wealthy speakers from dominating -- is not a valid reason to restrict speech
3. Corruption means only quid pro quo (explicit bribery), not the broader "undue influence" that spending creates

The strict scrutiny test applied:

• Is there a compelling government interest? (Yes -- preventing corruption)
• Is the restriction narrowly tailored? (No -- banning all corporate independent spending is too broad)
• Result: The ban on corporate independent expenditures fails strict scrutiny

SpeechNow.org v. FEC (2010): A federal appeals court applied Citizens United's logic to create Super PACs -- if independent expenditures can't corrupt, then contributions to groups making only independent expenditures can't be limited either.

The Legal Framework -- Before and After:

Buckley v. Valeo (1976) set the original rules:

• Spending money to express political views is protected speech
• The government CAN limit direct contributions to candidates (to prevent corruption)
• The government CANNOT limit independent expenditures (spending that isn't coordinated with a campaign)

Citizens United extended Buckley's logic:

1. If independent spending is protected for individuals (Buckley), it must be protected for corporations too (Citizens United)
2. The "anti-distortion" rationale -- preventing wealthy speakers from dominating -- is not a valid reason to restrict speech
3. Corruption means only quid pro quo (explicit bribery), not the broader "undue influence" that spending creates

The strict scrutiny test applied:

• Is there a compelling government interest? (Yes -- preventing corruption)
• Is the restriction narrowly tailored? (No -- banning all corporate independent spending is too broad)
• Result: The ban on corporate independent expenditures fails strict scrutiny

SpeechNow.org v. FEC (2010): A federal appeals court applied Citizens United's logic to create Super PACs -- if independent expenditures can't corrupt, then contributions to groups making only independent expenditures can't be limited either.