title: The Imaginarium of Doctor Parnassus

text: Gilliam finished editing the film by November 2008, and then work began on creating 647 computer generated imagery effects shots. As usual with his films, Gilliam found inspiration in particular painters for each CGI-generated scene inside the titular "Imaginarium". According to "Designing the Imaginarium" published by CBSnews.com, the scene with Doctor Parnassus's attempted suicide related to the style of Odd Nerdrum, the "Ladder World" with Jude Law featuring "rolling hills with simple trees" was inspired by the art of Grant Wood, the kitsch landscape from the beginning of the sequence with Colin Farrell took inspiration from Maxfield Parrish, and Jose Maria Sert's mural of the Crucifixion in Rockefeller Center inspired the scene including the final minutes of Farrell's appearance in the film.


title: The Imaginarium of Doctor Parnassus

text: According to the official "ParnassusFilm" Twitter channel launched on 30 March 2009, post-production was finished on 31 March. After the production had finally come to a successful closure, Gilliam felt that ""[I]" didn't make this film. Forces from above and below made it. It made itself. I don't worry anymore. It's got its own relentless momentum. It just needed some human sacrifice." "It's made itself – I was just one pair of hands and there were many hands." "Don't get me into my mystical mode [...] but the film made itself and it was co-directed by Heath Ledger!" "The irony is that the choices that were forced upon us improved the movie, so it was as if Heath co-directed the movie, even co-wrote it." According to Gilliam, actor Colin Farrell also went on record for saying that he hadn't been simply playing the character of Tony, but that he was rather feeling like "channeling Heath".


title: The Imaginarium of Doctor Parnassus

text: Gilliam also positively recalled people's commitment to Ledger's memory: "Everyone in the cast and everyone in the crew was determined that this film would be finished and everybody worked longer, harder and somehow we got through. It was really [...] people's love for Heath that propelled this thing forward." "All the actors already in the film had to change their schedules, and there wasn't a moment's hesitation. "[...]" They all said, 'We'll do what's necessary.' It's really a love letter to Heath by everybody involved. He was beloved by so many."


title: The Imaginarium of Doctor Parnassus

text: The film opens with St Paul's Cathedral in the background (by the north bank of the Thames), and the first show is performed under the rail tracks at Green Dragon Court, directly next to Borough Market, with Southwark Cathedral in the background (in Borough, London, on the south bank of the Thames), where the drunken lout molests the performers and then enters the mirror. The next scene, with Tower Bridge in the background, is just east along the riverbank, by City Hall. Tony is found hanging under Blackfriars Bridge, and the very large disused building in which the following scene (and several later ones) occurs is the interior of Battersea power station, farther west along the south bank of the river.


title: The Imaginarium of Doctor Parnassus

text: The following scenes occur north of the Thames: the Homebase, DIY store at 3 Station Road, south of New Southgate railway station, in New Southgate, followed by the Horseshoe pub in Clerkenwell Close in Clerkenwell from which the wagon flees. The restyled show makes its debut in Leadenhall Market, where the stylish women gather to watch. Bray Studios near Windsor was used for model shooting and additional photography.


title: The Imaginarium of Doctor Parnassus

text: The remaining scenes were filmed in Vancouver. The fantasy scenes were filmed at Bridge Studios in Burnaby, while the charity gala occurs at the Orpheum Theatre, and the glass-walled "mall" is the Central Branch of the Vancouver Public Library, the curved arcade being the library's entrance foyer.


title: The Imaginarium of Doctor Parnassus

text: The original motion picture soundtrack of "The Imaginarium of Doctor Parnassus" was composed by Mychael Danna and Jeff Danna who had previously worked on Gilliam's "Tideland" (2005). Gilliam wrote lyrics for the two songs "We Love Violence" and "We Are the Children of the World", the latter of which spoofed Michael Jackson's famous "We Are the World" and was nominated for a 2009 Satellite Award in the category "Best Original Song".


title: The Imaginarium of Doctor Parnassus

text: The song "We Love Violence", performed in the film by policemen in drag, was sung by Gilliam, Mick Audsley (who edited the film), the musician Ray Cooper, Ed Hall (who was also the Visual Effects Editor), and Andre Jacquemin (who was Supervising Sound & Design on the film).


title: The Imaginarium of Doctor Parnassus

text: Before it was finished, the film had already received healthy interest from worldwide distributors and had sold out across the world. However, it received mild response from many distributors in the United States. Gilliam said that Fox Searchlight Pictures and other distributors had declined to release it in the US. Eventually, its US distribution rights were acquired by Sony Pictures Worldwide Acquisitions Group, which released it in the US through Sony Pictures Classics. The US was the last territory in which it was sold. Gilliam said that his team asked for $4 million for selling the US rights, but eventually couldn't get it.


title: The Imaginarium of Doctor Parnassus

text: According to Reuters, the film debuted at No. 3 on its first weekend at the UK box office. The film debuted at No. 2 in both France and Italy, generating the year's third-best box office return on an opening weekend in Italy. Said Roberto Proia, distribution chief of the film's Italian distributor Moviemax, about its surprisingly warm reception, "Almost two years after his death, Ledger has a huge fanbase which, along with the rest of the stellar cast, certainly contributed hugely. [...] We also found out that teenagers massively love Gilliam, and we did not expect this. He really has rock star status." Eventually, the film had earned about $54,119,168 theatrically in the countries outside North America.


title: The Imaginarium of Doctor Parnassus

text: It earned $415,233 on its North American limited opening Christmas weekend (25–27 December 2009), being presented in 48 theatres with an average of $8,651. Its second weekend (1–3 January 2010) set an average of $7,684 with a gross of $368,836 which totaled $1,029,821 domestically. Releasing in 607 North American theatres, it took eleventh place on its opening wide release box office weekend (8–10 January 2010) with earnings of $1,762,637, an average of only $2,904 and a total of $2,989,290. Eventually, the film had earned $7,689,607 theatrically in North America.


title: The Imaginarium of Doctor Parnassus

text: According to the working partner of William Vince, the film had already made its budget back even before it opened in North America.


title: The Imaginarium of Doctor Parnassus

text: The film was released on DVD and Blu-ray in the United Kingdom (Region 2) on 29 March 2010, by Lionsgate Home Entertainment. Supplementary material includes an audio commentary and an introduction by Gilliam, deleted scenes, wardrobe test for Heath Ledger, visual FX feature, and three featurettes titled "Behind the Mirror", "Building the Temple", and "UK Premiere".


title: The Imaginarium of Doctor Parnassus

text: The DVD and Blu-ray were released in the US on 27 April 2010. The film went on to bigger success in US ancillary markets, with more than $10,445,997 in US Blu-ray and DVD sales alone.


title: The Imaginarium of Doctor Parnassus

text: Review aggregator Rotten Tomatoes reports that 64% of 197 critics have given the film a positive review, with a rating average of 5.97/10. The website's critical consensus is that "Terry Gilliam remains as indulgent as ever, but "The Imaginarium of Doctor Parnassus" represents a return to the intoxicatingly imaginative, darkly beautiful power of his earlier work, with fine performances to match all the visual spectacle." Metacritic, which assigns a normalised rating out of 100 to reviews from film critics, has a rating score of 65 based on 30 reviews, indicating 'generally favourable reviews'.


title: Free (band)

text: Free were an English rock band formed in London in 1968, best known for their hit songs "All Right Now" and "Wishing Well". Although renowned for their live shows and non-stop touring, their studio albums did not sell very well until their third, "Fire and Water" (1970), featured the massive hit "All Right Now". The song helped secure them a place at the Isle of Wight Festival 1970, where they played to an audience of 600,000 people. In the early 1970s they became one of the biggest-selling British blues rock groups; by the time they disbanded, they had sold more than 20 million records worldwide and had played more than 700 arena and festival concerts. "All Right Now" remains a R&B staple, and has been entered in ASCAP's "One Million" airplay singles club.


title: Free (band)

text: The band disbanded in 1973; lead singer Paul Rodgers went on to become the frontman of the more successful rock supergroup Bad Company, which also featured his Free bandmate Simon Kirke on drums. Guitarist Paul Kossoff formed Back Street Crawler in 1973, but died from a pulmonary embolism at the age of 25 in 1976. Bassist Andy Fraser formed Sharks.


title: Free (band)

text: "Rolling Stone" has referred to the band as "British hard rock pioneers". The magazine ranked Rodgers No. 55 in its list of the "100 Greatest Singers of All Time", and Paul Kossoff at Number 51 in its "100 Greatest Guitarists of All Time". Free were signed to Island Records in the UK and A&M Records in North America.


title: Free (band)

text: Paul Kossoff and Simon Kirke first became friends in the R&B band Black Cat Bones, but they wanted to move on. Kossoff saw vocalist Paul Rodgers singing with the band Brown Sugar while visiting the Fickle Pickle, an R&B club in London's Finsbury Park. He was immediately impressed and asked if he could jam with Rodgers onstage. Along with Kirke, they began the search for a fourth member. Alexis Korner recommended Andy Fraser to the band, who had already been playing with John Mayall & the Bluesbreakers. Korner also provided the name "Free" to the newly formed band.


title: Free (band)

text: The group played their first gig on 19 April 1968 at the Nag's Head pub, which was at the junction of York Road and Plough Road in Battersea, London. All members were relatively young. Bass player Andy Fraser was 15 years old, lead guitarist Paul Kossoff was 17, and both lead singer Paul Rodgers and drummer Simon Kirke were 18. By November of that year they had recorded their first album, titled "Tons of Sobs", for Island Records, although it was not released until the following year. The album documents their first six months together and contains studio renditions of much of their early live set. To promote their forthcoming debut album they also opened some gigs at the end of 1968 for the Who, who played a short theatre tour with Arthur Brown. The group's second studio album, "Free", was recorded and released in 1969 on Island Records.


title: Free (band)

text: Unlike their previous albums, "Tons of Sobs" and "Free", their album "Fire and Water", released in 1970, was a huge success largely due to its hit single "All Right Now", which reached No. 1 on the UK rock music charts, No. 2 on the UK singles chart and No. 4 on the US "Billboard" Hot 100. The album reached No. 2 in the UK charts and No. 17 on the U.S charts, making it the most successful Free album. "All Right Now" became a No. 1 hit in over 20 territories and was recognised by ASCAP in 1990 for garnering 1,000,000 plus radio plays in the US by late 1989. In 2000 an award was given to Paul Rodgers by the British Music Industry when "All Right Now" passed 2,000,000 radio plays in the UK.


title: Free (band)

text: In July 1970 the band, despite their name, were the only advertised band to decline to perform for free for the ailing Phun City festival - according to promoter Mick Farren they "heard the deal and fucked off without even getting out of the car." Kirke's replacement in Black Cat's Bones, Phil Lenoir, played the festival as drummer for Shagrat.


title: Free (band)

text: "Highway" was their fourth studio album, recorded extremely quickly in September 1970. "Highway" performed poorly in the charts, reaching No. 41 in the UK and No. 190 in the US.


title: Free (band)

text: The band disbanded in 1971 because of differences between Fraser and Rodgers, who felt he was not being listened to. This led to the release of the live album called "Free Live!" In early 1972 the band set aside their differences and reformed in an effort to save Kossoff from his growing drug addiction, and released "Free at Last" in June of the same year.


title: Free (band)

text: Fraser left the band in mid-1972, frustrated by Kossoff's unreliability at being able to perform at shows or even at showing up. The remaining members recruited Japanese bass player Tetsu Yamauchi and keyboardist John "Rabbit" Bundrick, who had worked with Kossoff and Kirke during Free's initial split, recording "Kossoff, Kirke, Tetsu and Rabbit" and recorded what would be Free's final album, "Heartbreaker". Kossoff was replaced by ex-Osibisa guitarist Wendell Richardson for a USA tour in 1973, but shortly thereafter Free disbanded for good. Rodgers and Kirke went on to form Bad Company, Fraser formed Sharks and later the Andy Fraser Band, and Kossoff formed Back Street Crawler.


title: Free (band)

text: With Kossoff in better health again in late 1975, he was delighted that ex-colleagues Rodgers and Kirke asked him to join them on stage for two nights. A British tour was set to begin on 25 April 1976 with Back Street Crawler headlining with Bad Company in support of Back Street Crawler's second album, but again Kossoff's drug addictions contributed to a drastic decline in the guitarist's health. On a flight from Los Angeles to New York City on 19 March 1976, Kossoff died from a pulmonary embolism at the age of 25.


title: Free (band)

text: After parting with Bad Company in 1982, Rodgers went on to explore the heavy blues stylings of Free again in his solo career during the 1980s and 1990s, and in the bands The Firm and The Law. Subsequently, he teamed up as vocalist with two of the three remaining members of Queen (Brian May and Roger Taylor). In September 2008, Queen + Paul Rodgers released their first studio album "The Cosmos Rocks". Rodgers also performed Free and Bad Company songs whilst on tour with Queen, in addition to the traditional Queen songs and new cuts from their most recently released album.


title: Free (band)

text: Rodgers and Kirke toured again with Bad Company from 2012 to 2016. Andy Fraser died on 16 March 2015. In 2017, Paul Rodgers embarked on a Free Spirit UK Tour in May 2017 to celebrate the music of Free by performing songs strictly from the Free catalogue. In 2019 Bad Company reformed to tour in support of the first leg on Lynyrd Skynyrd's Last Of The Street Survivors Tour.


title: Young Money Entertainment

text: Young Money Entertainment is an American record label founded by rapper Lil Wayne. Young Money's president is Lil Wayne's lifelong friend and fellow rapper Mack Maine. The label was an imprint of Cash Money Records and is distributed by Republic Records.


title: Young Money Entertainment

text: The label has released fourteen US albums that reached number one on the "Billboard" 200 chart: "Tha Carter III", "I Am Not a Human Being", "Tha Carter IV" and "Tha Carter V" by Lil Wayne, "Thank Me Later", "Take Care", "Nothing Was the Same", "If You're Reading This It's Too Late", "What a Time to Be Alive" (along with Epic Records artist Future), "Views", "More Life" and "Scorpion" by Drake, and "Pink Friday" and "" by Nicki Minaj.


title: Young Money Entertainment

text: Current artists include Lil Wayne, Nicki Minaj, Mack Maine, Lil Twist, and Cory Gunz, among others. The label has released three compilation albums — "We Are Young Money" (2009), "Rich Gang" (2013; with Cash Money Records), and "" (2014).


title: Young Money Entertainment

text: The label was formed in 2005. In 2007, In an interview with "Vibe" magazine, Lil Wayne detailed he stepped down as President of the label, and had given the position to Cortez Bryant. As of 2009, Mack Maine is serving as president. Canadian rapper Drake signed a joint venture between Cash Money Records and Young Money. President Mack Maine confirmed that Omarion was no longer on the label after many rumours were circulating the internet.


title: Young Money Entertainment

text: To promote the label's first collaboration album, "We Are Young Money", Young Money artists embarked on the Young Money Tour. The collaborative album was released on December 21, 2009, and debuted at number nine on the US "Billboard" 200 chart, selling 142,000 copies in its first-week sales. The album was certified gold by the Recording Industry Association of America (RIAA) for selling over a shipments of 500,000 copies in the United States.


title: Young Money Entertainment

text: "We Are Young Money" featured the highly successful single "BedRock", which debuted at thirty six on the "Billboard" Hot 100 on the week ending December 12, 2009. On the week ending March 13, 2010, the song reached a peak of two, making it the most successful single by the group on the chart.


title: Young Money Entertainment

text: "BedRock" debuted in the UK Singles Chart on February 6, 2010, at forty. On March 6, 2010, the single climbed to twenty two, and the subsequent week the single climbed to eighteen, marking Young Money's first Top 20 hit in the UK. Peaking at number nine on April 3, 2010, making it Young Money's first Top 10 hit in the UK.


title: Young Money Entertainment

text: The label had three of the top 10 highest 2010 hip hop album sales with Drake's "Thank Me Later", and Lil Wayne's "Rebirth" and "I Am Not a Human Being".


title: Young Money Entertainment

text: On March 6, 2010, Lil Wayne confirmed that rapper Cory Gunz was the latest artist to sign. In 2011, Konvict Muzik artist T-Pain signed to the Young Money roster after he and Akon agreed to part ways after his last Konvict release "RevolveR". Later that year, T-Pain revealed that he was close to signing a deal with Young Money, but it never concluded. In November 2011, Lil Wayne introduced 14-year-old singer Torion Sellers to Young Money.


title: Young Money Entertainment

text: On February 15, 2013, Mack Maine announced group We the Future and Lil Wayne's 14-year-old daughter Reginae Carter had signed to Young Money. In the same year, Young Money released Lil Wayne's "I Am Not a Human Being II", Tyga's "Hotel California" and Drake's "Nothing Was the Same" on March 26, April 7, and September 24, respectively.


title: Young Money Entertainment

text: In December 2012 Mack Maine announced a second Young Money album would be released. In February 2013, label co-owner Birdman released a compilation mixtape with Cash Money and Young Money titled "Rich Gang: All Stars". Shortly after, Birdman announced compilation album "Rich Gang" and its schedule for release to be on May 21, 2013. He added "Rich Gang" would feature members of Cash Money, Young Money and various Young Money collaborators. The first single from the project, "Tapout", was released on March 12, 2013, and featured Lil Wayne, Future, Mack Maine, and Nicki Minaj and produced by 808 Mafia's Southside and TM88. The album would then be pushed back to July 23, 2013.


title: Young Money Entertainment

text: On January 22, 2014, it was revealed that Young Money would be releasing their own compilation album on March 11, 2014, titled "". That same day, the first single "We Alright" featuring Lil Wayne, Birdman and Euro was released. Drake's "Nothing Was the Same" leftover "Trophies" would also be included on the album.


title: Young Money Entertainment

text: The album's second single, "Senile", was released February 14, 2014. It is by Tyga, Nicki Minaj and Lil Wayne and was produced by David D.A. Doman. "Trophies" and Minaj's "Lookin Ass" were met with more chart success than the first two singles.


title: Young Money Entertainment

text: After years of tensions with Birdman and Universal Music Group over unpaid advances and rights to his catalogue, Lil Wayne filed for lawsuit in 2015 initially for $51 million. In 2018, Lil Wayne and Universal settled, which detailed Lil Wayne would be compensated over $10 million from previously failed payments, and Young Money's ownership would be transferred from Cash Money to Universal directly. Additionally, Birdman's 49 percent ownership in Young Money would be transferred to Wayne, which took effect on September 13, 2018.


title: Young Money Entertainment

text: In June 2020, Lil Wayne, through the Young Money name, sold his master recordings in a settlement from Republic Records to its overhead company, Universal Music Group for $100 million. It was confirmed later in December when, arising out of recent court filings from Lil Wayne's lawsuit with his former manager Ronald Sweeney, that the settlement not only included his masters, but also the entire Young Money Entertainment catalog, including Nicki Minaj, Drake, Tyga, among other artists in their roster. As of December 2020, UMG reportedly owns all of Drake's pre-2018 album catalogue that has been released with the Young Money record label.


title: Asafoetida

text: is the dried latex (gum oleoresin) exuded from the rhizome or tap root of several species of "Ferula", perennial herbs growing tall. They are part of the celery family, Umbelliferae. Asafoetida is thought to be in the same genus as silphium, a North African plant now believed to be extinct, and was used as a cheaper substitute for that historically important herb from classical antiquity. The species are native to the deserts of Iran and mountains of Afghanistan where substantial amounts are grown.


title: Asafoetida

text: Asafoetida has a pungent smell, as reflected in its name, lending it the trivial name of "stinking gum". The odor dissipates upon cooking; in cooked dishes, it delivers a smooth flavour reminiscent of leeks or other onion relatives. Asafoetida is also known colloquially as "devil's dung" in English (and similar expressions in many other languages).


title: Asafoetida

text: It is called () in Tamil, () in Marathi, "hing (ہینگ)" in Urdu, yang’eh/ینگہہ in Kashmiri language, () in Odia, () in Bengali, () in Kannada, () in Malayalam (it was attested as in the 14th century), () in Telugu, and () in Hindi. In Pashto, it is called (). Its pungent odour has resulted in its being known by many unpleasant names. In French it is known (among other names) as , meaning 'shit of the Devil'. In English it is sometimes called "Devil's dung", and equivalent names can be found in most Germanic languages (e.g., German , Swedish , Dutch , and Afrikaans ). In Finnish, it is ('Devil's shit') or (Devil's resin'); in Turkish, , ('Satan's shit') or ('Satan's weed'); Also, it is called or () (lit. 'you got sick') in Hebrew; and in Kashubian it is called . Other names for it include "ting" and "haltit" or "tyib" in Arabic, and "hingu" in Malay.


title: Asafoetida

text: Typical asafoetida contains about 40–64% resin, 25% endogeneous gum, 10–17% volatile oil, and 1.5–10% ash. The resin portion is known to contain asaresinotannols A and B, ferulic acid, umbelliferone and four unidentified compounds. The volatile oil component is rich in various organosulfide compounds, such as 2-butyl-propenyl-disulfide, diallyl sulfide, diallyl disulfide (also present in garlic) and dimethyl trisulfide, which is also responsible for the odor of cooked onions. The organosulfides are primarily responsible for the odor and flavor of asafoetida.


title: Asafoetida

text: Many "Ferula" species are utilized as the sources of asafoetida. Most of them are characterized by abundant sulfur-containing compounds in the essential oil.


title: Asafoetida

text: This spice is used as a digestive aid, in food as a condiment, and in pickling. It plays a critical flavoring role in South Asian vegetarian cuisine by acting as a savory enhancer. Used along with turmeric, it is a standard component of lentil curries, such as dal, chickpea curries, and vegetable dishes, especially those based on potato and cauliflower. Asafoetida is used in vegetarian Indian cuisine where it enhances the flavor of numerous dishes, where it is quickly heated in hot oil before sprinkling on the food. Kashmiri cuisine also uses it in lamb/mutton dishes such as rogan josh. It is sometimes used to harmonise sweet, sour, salty, and spicy components in food. The spice is added to the food at the time of tempering. Sometimes dried and ground asafoetida (in small quantities) can be mixed with salt and eaten with raw salad.


title: Asafoetida

text: In its pure form, it is sold in the form of chunks of resin, small quantities of which are scraped off for use. The odor of the pure resin is so strong that the pungent smell will contaminate other spices stored nearby if it is not stored in an airtight container.


title: Asafoetida

text: The resin-like gum comes from the dried sap extracted from the stem and roots, and is used as a spice. The resin is greyish-white when fresh, but dries to a dark amber colour. The asafoetida resin is difficult to grate and is traditionally crushed between stones or with a hammer. Today, the most commonly available form is compounded asafoetida, a fine powder containing 30% asafoetida resin, along with rice flour or "maida" (white wheat flour) and gum arabic.


title: Asafoetida

text: "Ferula assa-foetida" is a monoecious, herbaceous, perennial plant of the family Apiaceae. It grows to high, with a circular mass of leaves. Stem leaves have wide sheathing petioles. Flowering stems are high and thick and hollow, with a number of schizogenous ducts in the cortex containing the resinous gum. Flowers are pale greenish yellow produced in large compound umbels. Fruits are oval, flat, thin, reddish brown and have a milky juice. Roots are thick, massive, and pulpy. They yield a resin similar to that of the stems. All parts of the plant have the distinctive fetid smell.


title: Asafoetida

text: Asafoetida was familiar in the early Mediterranean, having come by land across Iran. It was brought to Europe by an expedition of Alexander the Great, who, after returning from a trip to northeastern ancient Persia, thought they had found a plant almost identical to the famed silphium of Cyrene in North Africa—though less tasty. Dioscorides, in the first century, wrote, "the Cyrenaic kind, even if one just tastes it, at once arouses a humour throughout the body and has a very healthy aroma, so that it is not noticed on the breath, or only a little; but the Median [Iranian] is weaker in power and has a nastier smell." Nevertheless, it could be substituted for silphium in cooking, which was fortunate, because a few decades after Dioscorides' time, the true silphium of Cyrene became extinct, and asafoetida became more popular amongst physicians, as well as cooks.


title: Asafoetida

text: Asafoetida is also mentioned numerous times in Jewish literature, such as the Mishnah. Maimonides also writes in the "Mishneh Torah" "In the rainy season, one should eat warm food with much spice, but a limited amount of mustard and asafoetida [ ]."


title: Asafoetida

text: Though it is generally forgotten now in Europe, it is still widely used in India. Asafoetida is mentioned in the Bhagavata Purana (7:5:23-24), which states that one must not have eaten hing before worshipping the deity. Asafoetida is eaten by Brahmins and Jains. Devotees of the Hare Krishna also use hing in their food, as they are not allowed to consume onions or garlic. Their food has to be presented to Lord Krishna for sanctification (to become Prasadam) before consumption and onions and garlic cannot be offered to Krishna.


title: Asafoetida

text: Asafoetida was described by a number of Arab and Islamic scientists and pharmacists. Avicenna discussed the effects of asafoetida on digestion. Ibn al-Baitar and Fakhr al-Din al-Razi described some positive medicinal effects on the respiratory system.


title: Asafoetida

text: After the fall of Rome, until the 16th century, asafoetida was rare in Europe, and if ever encountered, it was viewed as a medicine. "If used in cookery, it would ruin every dish because of its dreadful smell", asserted Garcia de Orta's European guest. "Nonsense", Garcia replied, "nothing is more widely used in every part of India, both in medicine and in cookery." During the Italian Renaissance, asafoetida was used as part of the exorcism ritual.


title: Citizens United v. FEC

text: Citizens United v. Federal Election Commission, 558 U.S. 310 (2010), was a landmark decision of the Supreme Court of the United States regarding campaign finance laws and free speech under the First Amendment to the U.S. Constitution. It was argued in 2009 and decided in 2010. The court held 5-4 that the free speech clause of the First Amendment prohibits the government from restricting independent expenditures for political campaigns by corporations, including nonprofit corporations, labor unions, and other associations.


title: Citizens United v. FEC

text: The case began after Citizens United, a conservative non-profit organization, sought to air and advertise a film critical of then Democratic presidential candidate Hillary Clinton shortly before the 2008 Democratic primary elections. Broadcasting the film would have been a violation of the 2002 Bipartisan Campaign Reform Act, which prohibited any corporation, non-profit organization or labor union from making an "electioneering communication" within 30 days of a primary or 60 days of an election, or making any expenditure advocating the election or defeat of a candidate at any time. Citizens United challenged the constitutionality of this law, and its case reached the Supreme Court.


title: Citizens United v. FEC

text: In a majority opinion joined by four other justices, Associate Justice Anthony Kennedy held that the Bipartisan Campaign Reform Act's prohibition of all independent expenditures by corporations and unions violated the First Amendment's protection of free speech. The court overruled "Austin v. Michigan Chamber of Commerce" (1990), which had allowed a prohibition on election spending by incorporated entities, as well as a portion of "McConnell v. FEC" (2003) that had upheld restricted corporate spending on "electioneering communications." The ruling effectively freed corporations (including incorporated non-profit organizations) to spend money on electioneering communications and to directly advocate for the election or defeat of candidates. In a dissenting opinion, Associate 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."


title: Citizens United v. FEC

text: The decision remains highly controversial, generating much public discussion and receiving strong support and opposition from various groups. Senator Mitch McConnell commended the decision, arguing that it represented "an important step in the direction of restoring the First Amendment rights". By contrast, former President Barack Obama stated that the decision "gives the special interests and their lobbyists even more power in Washington". The 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", which authorized the creation of "Independent Expenditure Committees", more commonly known as Super PACs, and for later rulings by the Roberts Court, including "McCutcheon v. FEC" (2014), striking down other campaign finance restrictions. While the long-term legacy of this case remains to be seen, early studies by political scientists have concluded that "Citizens United" worked in favor of the electoral success of Republican candidates.


title: Citizens United v. FEC

text: the incorporated non-profit organization Citizens United wanted to air a film that was critical of Hillary Clinton and to advertise the film during television broadcasts, in violation of the 2002 Bipartisan Campaign Reform Act, commonly known as the McCain–Feingold Act or "BCRA" (pronounced "bik-ruh"), which prohibited "electioneering communications" by incorporated entities. Section 203 of BCRA 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 unions. The United States District Court for the District of Columbia held that §203 of BCRA applied and prohibited Citizens United from paying to have the film "" shown on television within 30 days of the 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 implementing WRTL". The Supreme Court reversed this decision, striking down those provisions of BCRA that prohibited corporations (including nonprofit corporations) and unions from making independent expenditures for "electioneering communications". The majority decision overruled "Austin v. Michigan Chamber of Commerce" (1990) and partially overruled "McConnell v. Federal Election Commission" (2003). The court, however, upheld requirements for public disclosure by sponsors of advertisements (BCRA §201 and §311). The case did not involve the federal ban on direct contributions from corporations or unions to candidate campaigns or political parties, which remain illegal in races for federal office.


title: Citizens United v. FEC

text: Section 203 of the Bipartisan Campaign Reform Act of 2002 (known as BCRA or McCain–Feingold Act) modified the Federal Election Campaign Act of 1971, to prohibit corporations and unions from using their general treasury to fund "electioneering communications" (broadcast advertisements mentioning a candidate in any context) within 30 days before a primary or 60 days before a general election. During the 2004 presidential campaign, Citizens United, a nonprofit 501(c)(4) organization, filed a complaint before the Federal Election Commission (FEC) charging that advertisements for Michael Moore's film "Fahrenheit 9/11", a docudrama critical of the Bush administration's response to the terrorist attacks on September 11, 2001, produced and marketed by a variety of corporate entities, 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 broadcast advertisements featuring a candidate within the proscribed time limits had actually been made. The FEC later dismissed a second complaint which argued that the movie itself constituted illegal corporate spending advocating the election or defeat of a candidate, which was illegal under the Taft–Hartley Act of 1947 and the Federal Election Campaign Act Amendments of 1974. In dismissing that complaint, the FEC found that:


title: Citizens United v. FEC

text: 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 the movie and advertisements for it would violate the Federal Election Campaign Act, because Citizens United was not a bona fide commercial film maker.


title: Citizens United v. FEC

text: In the wake of these decisions, Citizens United sought to establish itself as a bona fide commercial film maker before the 2008 elections, producing several documentary films between 2005 and 2007. By early 2008, it sought to run three television advertisements to promote its political documentary "Hillary: The Movie" and to air the movie on DirecTV.


title: Citizens United v. FEC

text: In December 2007, Citizens United filed a complaint in U.S. District Court for the District of Columbia challenging the constitutionality of several statutory provisions governing "electioneering communications". It asked the court to declare that the prohibition on corporate and union funding were facially unconstitutional, and also as applied to "Hillary: The Movie" and to the 30-second advertisement for the movie, and to 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.". It also sought to enjoin funding, disclosure and disclaimer requirements as applied to Citizens United's intended ads for the movie.


title: Citizens United v. FEC

text: In accordance with special rules in section 403 of the BCRA, a three-judge panel was convened to hear the case. On January 15, 2008, the court denied Citizens United's 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 Senator Clinton, that it was therefore express advocacy, not entitled to exemption from the ban on corporate funding of electioneering communications. The court held that the Supreme Court in "McConnell v. FEC" (2003) had found the disclosure requirements constitutional as to all electioneering communications, and "Wisconsin RTL" did not disturb this holding because the only issue of that case was whether speech that did not constitute the functional equivalent of express advocacy could be banned during the relevant pre-election period. However, Citizens United's complaint that § 203 of the BCRA violates the First Amendment as applied to the 30-second advertisement "Questions" was denied as moot, since "The FEC, in its filings and at oral argument, conceded that the advertisement is exempt from the Prohibition".


title: Citizens United v. FEC

text: On July 18, 2008, the District Court granted summary judgment to the Federal Election Commission. In accordance with the special rules in BCRA, Citizens United appealed to the Supreme Court which docketed the case on August 18, 2008 and noted probable jurisdiction on November 14, 2008.


title: Citizens United v. FEC

text: The Supreme Court heard oral argument on March 24, 2009 and then asked for further briefs on June 29; the re-argument was heard on September 9, 2009.


title: Citizens United v. FEC

text: During the original oral argument, Deputy Solicitor General Malcolm L. Stewart (representing the FEC) argued that under "Austin v. Michigan Chamber of Commerce", 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. In response to this line of questioning, 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.


title: Citizens United v. FEC

text: According to a 2012 article in "The New Yorker" by Jeffrey Toobin, the court expected after oral argument to rule on the narrow question that had originally been presented—Can Citizens United show the film? At the subsequent 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, with Chief Justice Roberts and Justices Scalia, Kennedy, Thomas and Alito in the majority.


title: Citizens United v. FEC

text: 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 Kennedy argued that the court could and 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.


title: Citizens United v. FEC

text: On the other side, John Paul Stevens, the most senior justice in the minority, assigned the dissent to David Souter, who announced his retirement from the court while he was working on it. The final draft went beyond critiquing the majority. Toobin described it as "air[ing] some of the Court's dirty laundry", writing that Souter's dissent accused Roberts of having manipulated court procedures to reach his desired result—an expansive decision that, Souter claimed, changed decades of election law and ruled on issues neither party to the litigation had presented.


title: Citizens United v. FEC

text: According to Toobin, Roberts agreed to withdraw the opinion and schedule the case for reargument. When he did, the "Questions Presented" to the parties were, however, more expansive, touching on the issues Kennedy's opinion had identified. According to Toobin, the eventual result was therefore a foregone conclusion from that point on. Toobin's account has been criticized for drawing conclusions unsupported by the evidence in his article.


title: Citizens United v. FEC

text: On June 29, 2009, the last day of the term, the court issued an order directing the parties to re-argue the case on September 9 after briefing whether it might be necessary to overrule "Austin" and/or "McConnell v. Federal Election Commission" to decide the case. Justice Stevens noted in his dissent that in its prior motion for summary judgment, Citizens United had abandoned its facial challenge of BCRA §203's constitutionality, with the parties agreeing to the dismissal of the claim.


title: Citizens United v. FEC

text: Justice Sotomayor sat on the bench for the first time during the second round of oral arguments. This was the first case argued by then-Solicitor General and future Supreme Court Justice Elena Kagan. Former Bush Solicitor General Ted Olson and First Amendment lawyer Floyd Abrams argued for Citizens United, and former Clinton Solicitor General Seth Waxman defended the statute on behalf of various supporters. Legal scholar Erwin Chemerinsky called it "one of the most important First Amendment cases in years".


title: Citizens United v. FEC

text: On January 21, 2010, the court issued a 5–4 decision in favor of Citizens United that struck down BCRA's restrictions on independent expenditures from corporate treasuries as violations of the First Amendment.


title: Citizens United v. FEC

text: Five justices formed the majority and joined an opinion written by Justice Anthony Kennedy. The court found that BCRA §203 prohibition of all independent expenditures by corporations and unions violated the First Amendment's protection of free speech. The majority 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."


title: Citizens United v. FEC

text: Justice Kennedy's opinion 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. The court overruled "Austin", which had held that a state law 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 that portion of "McConnell" that upheld BCRA's restriction of corporate spending on "electioneering communications". The court's ruling effectively freed corporations and unions to spend money both on "electioneering communications" and to directly advocate for the election or defeat of candidates (although not to contribute directly to candidates or political parties).


title: Citizens United v. FEC

text: The majority ruled that the Freedom of the 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 "Buckley v. Valeo", limiting a corporation's ability to spend money is unconstitutional, because it limits the ability of its members to associate effectively and to speak on political issues.


title: Citizens United v. FEC

text: The decision overruled "Austin" both because that decision allowed an absolute prohibition on corporate electoral spending, and because it permitted different restrictions on speech-related spending based on corporate identity. Most importantly, the decision said that "Austin" was based on an "equality" rationale—trying to equalize speech between different speakers—that the court had previously rejected as illegitimate under the First Amendment in "Buckley". The Michigan statute at issue in "Austin" had distinguished between corporate and union spending, prohibiting the former while allowing the latter. The "Austin" court, over the dissent by Justices Scalia, Kennedy, and O'Connor, had held that such distinctions were within the legislature's prerogative. In "Citizens United v. Federal Election Commission", however, the majority argued that the First Amendment purposefully keeps the government from interfering in the "marketplace of ideas" and "rationing" speech, and it is not up to the legislatures or the courts to create a sense of "fairness" by restricting speech.


title: Citizens United v. FEC

text: The majority also 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: "There is no such thing as too much speech." The public has a right to have access to all information and to determine the reliability and importance of the information. Additionally, the majority did not believe that reliable evidence substantiated the risk of corruption or the appearance of corruption, and so this rationale did not satisfy strict scrutiny.


title: Citizens United v. FEC

text: The court's opinion relied heavily on the reasoning and principles of the landmark campaign finance case of "Buckley" and "First National Bank of Boston v. Bellotti", in which the court struck down a broad prohibition against independent expenditures by corporations in ballot initiatives and referendums. Specifically, the court echoed "Bellotti's" rejection of categories based on a corporation's purpose. The majority argued that to grant Freedom of the Press protections to media corporations, but not others, presented a host of problems; and so all corporations should be equally protected from expenditure restrictions.


title: Citizens United v. FEC

text: The court found that BCRA §§201 and 311, provisions requiring disclosure of the funder, were valid as applied to the movie advertisements and to the movie itself. The majority ruled for the disclosure of the sources of campaign contributions, saying thatprompt 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 ... This transparency enables the electorate to make informed decisions and give proper weight to different speakers and messages.


title: Citizens United v. FEC

text: 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".


title: Citizens United v. FEC

text: Roberts wrote to further explain and defend the court's statement that "there is a difference between judicial restraint and judicial abdication." Roberts explained why the court must sometimes overrule prior decisions. Had prior courts never gone against "stare decisis" (that is, 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".


title: Citizens United v. FEC

text: Justice Scalia joined the opinion of the court, and wrote a concurring opinion which Justice Alito joined in full and Justice Thomas joined in part. Scalia addressed Justice Stevens' dissent, 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 Framers' views about the "role of corporations in society" to be misleading, and even if valid, irrelevant to the text. Scalia principally 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." Scalia argued that the Free Press clause was originally intended to protect the distribution of written materials and did not only apply to the media specifically. This understanding supported the majority's contention that the Constitution does not allow the court to separate corporations into media and non-media categories.


title: Citizens United v. FEC

text: Justice Thomas wrote a separate opinion concurring in all but the upholding of the disclosure provisions. In order to protect the anonymity of contributors to organizations exercising free speech, Thomas would have struck down 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 was that anonymous free speech is protected and that making contributor lists public makes the contributors vulnerable to retaliation, citing instances of retaliation against contributors to both sides of a then-recent California voter initiative. Thomas also expressed concern that such retaliation could extend to retaliation by elected officials. Thomas did not consider "as-applied challenges" to be sufficient to protect against the threat of retaliation.


title: Citizens United v. FEC

text: A dissenting opinion by Justice Stevens was joined by Justice Ginsburg, Justice Breyer, and Justice Sotomayor. To emphasize his unhappiness with the majority, Stevens read part of his 90-page dissent from the bench. Stevens concurred in the court's decision to sustain BCRA's disclosure provisions but dissented from the principal holding of the court. He argued 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." He added: "A democracy cannot function effectively when its constituent members believe laws are being bought and sold."


title: Citizens United v. FEC

text: Stevens also argued that the court addressed a question not raised by the litigants when it found BCRA §203 to be facially unconstitutional, and that the majority "changed the case to give themselves an opportunity to change the law". He argued that the majority had expanded the scope beyond the questions presented by the appellant and that therefore a sufficient record for judging the case did not exist. Stevens argued that at a minimum the court should have remanded the case for a fact-finding hearing, and that the majority did not consider other compilations of data, such as the Congressional record for justifying BCRA §203.


title: Citizens United v. FEC

text: 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". 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. Although the majority echoed many of the arguments in "First National Bank of Boston v. Bellotti", Stevens argued that the majority opinion contradicted the reasoning of other campaign finance cases—in particular, of course, the two cases the majority expressly overruled, "Austin v. Michigan State Chamber of Commerce" and "McConnell v. Federal Election Commission."


title: Citizens United v. FEC

text: Stevens argued that the majority failed to recognize the possibility for corruption outside strict "quid pro quo" exchanges. He referenced the record from "McConnell v. FEC" to argue that, even if the exchange of votes for expenditures could not be shown, contributors gain favorable political access from such expenditures. The majority, however, considered mere access to be an insufficient justification for limiting speech rights.


title: Citizens United v. FEC

text: Stevens responded that in the past, even when striking down a ban on corporate independent expenditures, the court "never suggested that such quid pro quo debts must take the form of outright vote buying or bribes" ("Bellotti"). "Buckley", he said, also acknowledged that large independent expenditures present the same dangers as "quid pro quo" arrangements, even though "Buckley" struck down limits on such independent expenditures. Using the record from "McConnell", 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. Furthermore, Stevens argued that corporations could threaten Representatives and Senators with negative advertising to gain unprecedented leverage, citing "Caperton v. A.T. Massey Coal Co.", (holding that $3 million in independent expenditures in a judicial race raised sufficient questions about a judge's impartiality to require the judge to recuse himself in a future case involving the spender). Stevens argued that it was contradictory for the majority to ignore the same risks in legislative and executive elections, and argued that the majority opinion would exacerbate the problem presented in "Caperton" because of the number of states with judicial elections and increased spending in judicial races.


title: Citizens United v. FEC

text: Second, 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 view corporate independent expenditures as a method used to gain unfair legislative access. Stevens predicted that if the public came to believe that corporations dominate elections, disaffected voters would stop participating.


title: Citizens United v. FEC

text: Third, Stevens argued that the majority's decision failed to recognize the dangers of the corporate form. "Austin" held that the prevention of corruption, including the distorting influence of a dominant funding source, was a sufficient reason for regulating corporate independent expenditures. In defending "Austin", Stevens argued that the unique qualities of corporations and other artificial legal entities made them dangerous to democratic elections. These legal entities, he argued, have perpetual life, the ability to amass large sums of money, limited liability, no ability to vote, no morality, no purpose outside profit-making, and no loyalty. Therefore, he argued, the courts should permit legislatures to regulate corporate participation in the political process.


title: Citizens United v. FEC

text: Legal entities, Stevens wrote, are not "We the People" for whom our Constitution was established. Therefore, he argued, they should not be given speech protections under the First Amendment. The First Amendment, he argued, protects individual self-expression, self-realization and the communication of ideas. Corporate spending is the "furthest from the core of political expression" protected by the Constitution, he argued, citing "Federal Election Commission v. Beaumont", and corporate spending on politics should be viewed as a business transaction designed by the officers or the boards of directors for no purpose other than profit-making. Stevens called corporate spending "more transactional than ideological". Stevens also pointed out that any member of a corporation may spend personal money on promoting a campaign because BCRA only prohibited the use of general treasury money.


title: Citizens United v. FEC

text: Stevens critiqued the majority's main argument that prohibiting limits on spending protects free speech and allows the general public to receive all available information. Citing "Austin", Stevens argued that corporations unfairly influence the electoral process with vast sums of money that few individuals can match. This process, he argued, puts disproportionate focus on supporting this type of speech and gives the impression of widespread acclaim regardless of actual support.


title: Citizens United v. FEC

text: Fifth, Stevens criticized the majority's fear that the government could use BCRA §203 to censor the media. The focus placed on this hypothetical fear made no sense to him because it did not relate to the facts of this case—if the government actually attempted to apply BCRA §203 to the media (and assuming that Citizens United could not constitute media), the court could deal with the problem at that time. Stevens described the majority's supposed protection of the media as nothing more than posturing. According to him, it was the majority's new rule in this case, that prohibited a law from distinguishing between speakers or funding sources. This new rule would be the only reason why media corporations could not be exempted from BCRA §203.


title: Citizens United v. FEC

text: Stevens recognized that "[t]he press plays a unique role not only in the text, history, and structure of the First Amendment but also in facilitating public discourse," and even grants that the majority "raised some interesting and difficult questions about Congress' authority to regulate electioneering by the press, and about how to define what constitutes the press." In response he argued (emphasis in original) ""that [this question of regulating and defining the press] is not the case before us."" Stevens's opinion expresses his view that the institutional press can be distinguished from other persons and entities that are not the press while the majority opinion viewed "freedom of the press" as an activity, applicable to all citizens or groups of citizens seeking to publish views. However, while Stevens has been interpreted as implying the press clause specifically protects the institutional press it isn't clear from his opinion. In footnote 62 Stevens does argue that the free press clause demonstrates "that the drafters of the First Amendment did draw distinctions—explicit distinctions—between types of "speakers", or speech outlets or forms" but the disjunctive form of the sentence doesn't clearly entail that the distinction must have been between types of speakers rather than outlets or forms.


title: Citizens United v. FEC

text: Sixth, Stevens claimed that the majority failed to give proper deference to the legislature. Stevens predicted that this ruling would restrict the ability of the states to experiment with different methods for decreasing corruption in elections. According to Stevens, this ruling virtually ended those efforts, "declaring by fiat" that people will not "lose faith in our democracy". Stevens argued that the majority's view of a self-serving legislature, passing campaign-spending laws to gain an advantage in retaining a seat, coupled with "strict scrutiny" of laws, would make it difficult for any campaign finance regulation to be upheld in future cases.


title: Citizens United v. FEC

text: Seventh, Stevens argued that the majority opinion ignored the rights of shareholders. A series of cases protects individuals from legally compelled payment of union dues to support political speech. Because shareholders invest money in corporations, Stevens argued that the law should likewise help to protect shareholders from funding speech that they oppose. The majority, however, argued that ownership of corporate stock was voluntary and that unhappy shareholders could simply sell off their shares if they did not agree with the corporation's speech. Stevens also argued that Political Action Committees (PACs), which allow individual members of a corporation to invest money in a separate fund, are an adequate substitute for general corporate speech and better protect shareholder rights. The majority, by contrast, argued that most corporations are too small and lack the resources and raw number of shareholders and management staff necessary to support the legal compliance, accounting and administrative costs of a PAC. In this dispute, the opposing views essentially discussed differing types of entities: Stevens focused his argument on large, publicly held corporations, while the majority, and particularly Justice Scalia's concurring opinion, placed an emphasis on small, closely held corporations and non-profits.


title: Citizens United v. FEC

text: Stevens called the majority's faith in "corporate democracy" an unrealistic method for a shareholder to oppose political funding. A derivative suit is slow, inefficient, risky and potentially expensive. Likewise, shareholder meetings only happen a few times a year, not prior to every decision or transaction. Rather, the officers and boards control the day-to-day spending, including political spending. According to Stevens, the shareholders have few options, giving them "virtually nonexistent" recourse for opposing a corporation's political spending. Furthermore, most shareholders use investment intermediaries, such as mutual funds or pensions, and by the time a shareholder may find out about a corporation's political spending and try to object, the damage is done and the shareholder has funded disfavored speech.


title: Citizens United v. FEC

text: The decision was highly controversial and remains a subject of widespread public discussion. There was a wide range of reactions to the case from politicians, academics, attorneys, advocacy groups and journalists.


title: Citizens United v. FEC

text: Senate Minority Leader Mitch McConnell, a plaintiff in the earlier related decision "McConnell v. FEC", said:


title: Citizens United v. FEC

text: Republican campaign consultant Ed Rollins opined that the decision adds transparency to the election process and will make it more competitive.


title: Citizens United v. FEC

text: 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." During litigation, Citizens United had support from the United States Chamber of Commerce and the National Rifle Association.


title: Citizens United v. FEC

text: Campaign finance attorney Cleta Mitchell, who had filed an amicus curiae 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."


title: Citizens United v. FEC

text: 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."


title: Citizens United v. FEC

text: Libertarian Cato Institute analysts 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". They continued, "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."


title: Citizens United v. FEC

text: The American Civil Liberties Union filed an amicus brief that supported the decision, saying that "section 203 should now be struck down as facially unconstitutional", though membership was split over the implications of the ruling, and its board sent the issue to its special committee on campaign finance for further consideration. On March 27, 2012, the ACLU reaffirmed its stance in support of the Supreme Court's "Citizens United" ruling.


title: Citizens United v. FEC

text: Bradley A. Smith, professor of law at Capital University Law School, former chairman of the FEC, founder of the Institute for Free Speech, and a leading proponent of deregulation of campaign finance, wrote that the major 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. In response to statements by President Obama and others that the ruling would allow foreign entities to gain political influence through U.S. subsidiaries, Smith pointed out that the decision did not overturn the ban on political donations by foreign corporations and the prohibition on any involvement by foreign nationals in decisions regarding political spending by U.S. subsidiaries, which are covered by other parts of the law.


title: Citizens United v. FEC

text: Campaign finance expert Jan Baran, a member of the Commission on Federal Ethics Law Reform, agreed with the decision, 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." Baran further noted that in general conservatives and libertarians praised the ruling's preservation of the First Amendment and freedom of speech, but that liberals and campaign finance reformers criticized it as greatly expanding the role of corporate money in politics.


title: Citizens United v. FEC

text: Attorney Kenneth Gross, former associate general counsel of the FEC, 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.


title: Citizens United v. FEC

text: "The New York Times" asked seven academics to opine on how corporate money would reshape politics as a result of the court's decision. Three of the seven wrote that the effects would be minimal or positive: Christopher Cotton, a University of Miami School of Business assistant professor of economics, 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. Eugene Volokh, a professor of law at UCLA, 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". 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".


title: Citizens United v. FEC

text: The Editorial Board of the "San Antonio Express-News" criticized McCain–Feingold's 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."


title: Citizens United v. FEC

text: Anthony Dick in "National Review" countered a number of arguments against the decision, asking rhetorically, "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". 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 are 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.


title: Citizens United v. FEC

text: "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."


title: Citizens United v. FEC

text: 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". 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". On January 27, 2010, Obama further condemned the decision during the 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." On television, the camera shifted to a shot of the SCOTUS judges in the front row directly in front of the President while he was making this statement, and Justice Samuel Alito was frowning, shaking his head side to side while mouthing the words "Not true".


title: Citizens United v. FEC

text: Democratic Senator Russ Feingold, a lead sponsor 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." Representative Alan Grayson, a Democrat, stated that it was "the worst Supreme Court decision since the "Dred Scott case", and that the court had opened the door to political bribery and corruption in elections to come. Democratic congresswoman Donna Edwards, along with constitutional law professor and Maryland Democratic State Senator Jamie Raskin, have advocated petitions to reverse the decision by means of constitutional amendment. Rep. Leonard Boswell introduced legislation to amend the constitution. Senator John Kerry also called for an Amendment to overrule the decision. On December 8, 2011, Senator Bernie Sanders proposed the Saving American Democracy Amendment, which would reverse the court's ruling.


title: Citizens United v. FEC

text: Republican Senator John McCain, co-crafter of the 2002 Bipartisan Campaign Reform Act and the party's 2008 presidential nominee, 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". 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." Republican Senator Olympia Snowe opined that "Today's decision was a serious disservice to our country."


title: Citizens United v. FEC

text: Although federal law after "Citizens United v. Federal Election Commission" still prohibited corporate contributions to all political parties, 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." Another Green Party officer, 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."


title: Citizens United v. FEC

text: 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." Writing for CounterPunch, he called for shareholder resolutions asking company directors to pledge not to use company money to favor or oppose electoral candidates.


title: Citizens United v. FEC

text: Pat Choate, former Reform Party candidate for Vice President, stated, "The court has, in effect, legalized foreign governments and foreign corporations to participate in our electoral politics."


title: Citizens United v. FEC

text: Senator Bernie Sanders, a contender in the 2016 Democratic Primary, has filed a constitutional amendment to overturn the Supreme Court's Decision. Further, both Sanders and Hillary Clinton said that, if they were elected, they would only have appointed Supreme Court Justices who were committed to the repeal of Citizens United. In September 2015, Sanders said that "the foundations of American Democracy are being undermined" and called for sweeping campaign finance reform. Sanders repeated such calls in the years since.


title: Citizens United v. FEC

text: When asked about the April 2014 ruling, former President Jimmy Carter called the United States "an oligarchy with unlimited political bribery" in an interview with Thom Hartmann.


title: Citizens United v. FEC

text: Ambassador Janez Lenarčič, speaking for the Organization for Security and Co-operation in Europe's Office for Democratic Institutions and Human Rights (which has overseen over 150 elections) said 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".


title: Citizens United v. FEC

text: 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, "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."


title: Citizens United v. FEC

text: Former 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. Federal Election Commission" 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."


title: Citizens United v. FEC

text: Richard L. Hasen, professor of election law at Loyola Law School, argued that the ruling "is activist, it increases the dangers of corruption in our political system and it ignores the strong tradition of American political equality". He also described Justice Kennedy's "specter of blog censorship" as sounding more like "the rantings of a right-wing talk show host than the rational view of a justice with a sense of political realism".


title: Citizens United v. FEC

text: Kathleen M. Sullivan, professor at Stanford Law School and Steven J. Andre, adjunct professor at Lincoln Law School, argued that two different visions of freedom of speech exist and clashed in the case. An egalitarian vision skeptical of the power of large agglomerations of wealth to skew the political process conflicted with a libertarian vision skeptical of government being placed in the role of determining what speech people should or should not hear. Wayne Batchis, Professor at the University of Delaware, in contrast, argues that the Citizens United decision represents a misguided interpretation of the non-textual freedom of association.


title: Citizens United v. FEC

text: The four other scholars of the seven writing in the aforementioned "The New York Times" article were critical. Richard L. Hasen, Distinguished Professor of election law at Loyola Law School argued differently from his Slate article above, concentrating on the "inherent risk of corruption that comes when someone spends independently to try to influence the outcome of judicial elections", since judges are less publicly accountable than elected officials. Heather K. Gerken, Professor of Law at Yale Law School wrote that "The court has done real damage to the cause of reform, but that damage mostly came earlier, with decisions that made less of a splash." Michael Waldman, director of the Brennan Center for Justice at N.Y.U. School of Law, opined that the decision "matches or exceeds "Bush v. Gore" in ideological or partisan overreaching by the court", explaining how "Exxon or any other firm could spend Bloomberg-level sums in any congressional district in the country against, say, any congressman who supports climate change legislation, or health care, etc." and Fred Wertheimer, founder and president of Democracy 21 considered that "Chief Justice Roberts has abandoned the illusory public commitments he made to 'judicial modesty' and 'respect for precedent' to cast the deciding vote for a radical decision that profoundly undermines our democracy", and that "Congress and presidents past have recognized this danger and signed numerous laws over the years to prevent this kind of corruption of our government."


title: Citizens United v. FEC

text: In a "Time" magazine survey of over 50 law professors, Richard Delgado (University of Alabama), Cass Sunstein (Harvard), and Jenny Martinez (Stanford) all listed "Citizens United" as the "worst Supreme Court decision since 1960", with Sunstein noting that the decision is "undermining our system of democracy itself."


title: Citizens United v. FEC

text: "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." Jonathan Alter called it the "most serious threat to American democracy in a generation". "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".


title: Citizens United v. FEC

text: In 2012, Ben Cohen, the co-founder of Ben & Jerry's ice cream, founded Stamp Stampede, a sustained protest to demonstrate widespread support for a proposed constitutional amendment to overturn "Citizens United". The campaign encourages people to rubber stamp messages such as "Not To Be Used for Bribing Politicians" on paper currency. In 2014, Cohen told "Salon", "As long as the Supreme Court rules money is speech, corporations and the wealthy are using it by giving piles of it to politicians to pass or not pass laws that they want. Now, the rest of the people, [those] who don't have that money, can actually make their voice heard by using money to stamp a message out."


title: Citizens United v. FEC

text: Most blogs avoided the theoretical aspects of the decision and focused on more personal and dramatic elements, including the Barack Obama–Samuel Alito face-off during the President's State of the Union address. There, President Obama argued that the decision "reversed a century of law" (the federal ban on corporate contributions dates back to the 1907 Tillman Act, and the ban on union and corporate expenditures dates from 1947) and that it would allow "foreign corporations to spend without limits in our elections", during which Justice Alito, in the audience, perceptibly mouthed the words "not true". This event received extensive comment from political bloggers, with a substantial amount of the coverage concentrated on whether or not foreign corporations would be able to make substantial political contributions in US elections. In the opinion, the court had specifically indicated it was not overturning the ban on foreign contributions.


title: Citizens United v. FEC

text: An ABC–"The Washington Post" poll conducted February 4–8, 2010, showed that 80% of those surveyed opposed (and 65% strongly opposed) the "Citizens United" ruling, which the poll described as saying "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.


title: Citizens United v. FEC

text: A Gallup Poll conducted in October 2009, after oral argument, but released after the Supreme Court released its opinion, found that 57 percent 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, respondents by 52% to 41% prioritized limits on campaign contributions over protecting rights to support campaigns and 76% thought the government should be able to place limits on corporation or union donations.


title: Citizens United v. FEC

text: Separate polls commissioned by various conservative organizations, including the plaintiff Citizens United and the Institute for Free Speech, using different wording, found support for the decision. In particular, the 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 percent had heard of the case.


title: Citizens United v. FEC

text: Polling conducted by Ipsos in August 2017 found that 48% of Americans oppose the decision and 30% support it, with the remainder having no opinion. It also found that 57% percent of Americans favored "limits on the amount of money super PACs can raise and spend".


title: Citizens United v. FEC

text: SpeechNow is a nonprofit, unincorporated association organized as a section 527 entity under the U.S. Internal Revenue Code. The organization was formed by individuals who seek to pool their resources to make independent expenditures expressly advocating the election or defeat of federal candidates. SpeechNow planned to accept contributions only from individuals, not corporations or other sources prohibited under the Federal Election Campaign Act. On February 14, 2008, SpeechNow and several individual plaintiffs filed a complaint in the U.S. District Court for the District of Columbia challenging the constitutionality of the Federal Election Campaign Act provisions governing political committee registration, contribution limits and disclosure. The plaintiffs contended that the Act unconstitutionally restricts their association guaranteed under the First Amendment. By requiring registration as a political committee and limiting the monetary amount that an individual may contribute to a political committee, SpeechNow and the other plaintiffs asserted that the Act unconstitutionally restricted the individuals' freedom of speech by limiting the amount that an individual can contribute to SpeechNow and thus the amount the organization may spend. SpeechNow also argued that the reporting required of political committees is unconstitutionally burdensome.


title: Citizens United v. FEC

text: On March 26, 2010, the U.S. Court of Appeals for the District of Columbia Circuit ruled in "SpeechNow.org. v. FEC" that the contribution limits of 2 U.S.C. §441a were unconstitutional as applied to individuals' contributions to SpeechNow. The court also ruled that the reporting requirements of 2 U.S.C. §§432, 433 and 434(a) and the organizational requirements of 2 U.S.C. §431(4) and §431(8) can be constitutionally applied to SpeechNow. A unanimous nine-judge panel of the United States Court of Appeals struck down the federal limits on contributions to federal political committees that make only independent expenditures and do not contribute to candidates or political parties. This type of "independent expenditure committee" is inherently non-corruptive, the court reasoned, and therefore contributions to such a committee can not be limited based on the government's interest in preventing political corruption. In light of the Supreme Court's decision in "Citizens United v. FEC", in which the Supreme Court held that the government has no anti-corruption interest in limiting independent expenditures, the appeals court ruled that "contributions to groups that make only independent expenditures cannot corrupt or create the appearance of corruption." As a result, the court of appeals held that the government has no anti-corruption interest in limiting contributions to an independent group such as SpeechNow. Contribution limits as applied to SpeechNow "violate the First Amendment by preventing [individuals] from donating to SpeechNow in excess of the limits and by prohibiting SpeechNow from accepting donations in excess of the limits." The court noted that its holding does not affect direct contributions to candidates, but rather contributions to a group that makes only independent expenditures. The appeals court held that, while disclosure and reporting requirements do impose a burden on First Amendment interests, they "'impose no ceiling on campaign related activities'" and "'do not prevent anyone from speaking.'" Furthermore, the court held that the additional reporting requirements that the Commission would impose on SpeechNow if it were organized as a political committee are minimal, "given the relative simplicity with which SpeechNow intends to operate." Since SpeechNow already had a number of "planned contributions" from individuals, the court ruled that SpeechNow could not compare itself to "ad hoc groups that want to create themselves on the spur of the moment." Since the public has an interest in knowing who is speaking about a candidate and who is funding that speech, the court held that requiring such disclosure and organization as a political committee are sufficiently important governmental interests to justify the additional reporting and registration burdens on SpeechNow.


title: Citizens United v. FEC

text: On June 27, 2011, ruling in the consolidated cases of "Arizona Free Enterprise Club's Freedom Club PAC v. Bennett" (No. 10-238) and "McComish v. Bennett" (No. 10-239), the Supreme Court deemed unconstitutional an Arizona law that provided extra taxpayer-funded support for office seekers who have been outspent by privately funded opponents or by independent political groups. A conservative 5–4 majority of justices said the law violated free speech, concluding the state was impermissibly trying to "level the playing field" through a public finance system. Arizona lawmakers had argued there was a compelling state interest in equalizing resources among competing candidates and interest groups. Opponents said the law violated free-speech rights of the privately financed candidates and their contributors, inhibiting fundraising and spending, discouraging participation in campaigns and limiting what voters hear about politics. Chief Justice John Roberts said in the court's majority opinion that the law substantially burdened political speech and was not sufficiently justified to survive First Amendment scrutiny.


title: Citizens United v. FEC

text: As a consequence of the decision, states and municipalities are blocked from using a method of public financing that is simultaneously likely to attract candidates fearful they will be vastly outspent and sensitive to avoiding needless government expense. "The government can still use taxpayer funds to subsidize political campaigns, but it can only do that in a manner that provides an alternative to private financing" said William R. Maurer, a lawyer with Institute for Justice, which represented several challengers of the law. "It cannot create disincentives." The ruling meant the end of similar matching-fund programs in Connecticut, Maine and a few other places according to David Primo, a political science professor at University of Rochester who was an expert witness for the law's challengers.


title: Citizens United v. FEC

text: Despite the "Citizens United" ruling, in December 2011, the Montana Supreme Court, in "Western Tradition Partnership, Inc. v. Attorney General of Montana", upheld that state's law limiting corporate contributions. Examining the history of corporate interference in Montana government that led to the Corrupt Practices Law, the majority decided that the state still had a compelling reason to maintain the restrictions. It ruled that these restrictions on speech were narrowly tailored and withstood strict scrutiny and thus did not contradict "Citizens United v. Federal Election Commission".


title: Citizens United v. FEC

text: While granting permission to file a certiorari petition, the US Supreme Court agreed to stay the Montana ruling, although Justices Ginsburg and Breyer wrote a short statement urging the court "to consider whether, in light of the huge sums of money currently deployed to buy candidate's allegiance, "Citizens United" should continue to hold sway". In June 2012, over the dissent of the same four judges who dissented in "Citizens United", the court simultaneously granted certiorari and summarily reversed the decision in "American Tradition Partnership, Inc. v. Bullock", 567, U.S. __ (2012). The Supreme Court majority rejected the Montana Supreme Court arguments in a two paragraph, twenty line per curiam opinion, stating that these arguments "either were already rejected in Citizens United, or fail to meaningfully distinguish that case." The ruling makes clear that states cannot bar corporate and union political expenditures in state elections.


title: Citizens United v. FEC

text: In addition to limiting the size of donations to individual candidates and parties, the Federal Election Campaign Act also includes aggregate caps on the total amount that an individual may give to all candidates and parties. In 2012, Shaun McCutcheon, a Republican Party activist, sought to donate more than was allowed by the federal aggregate limit on federal candidates. McCutcheon "et al" filed suit against the Federal Election Commission (FEC). In 2014, the US Supreme Court reversed a ruling of the DC District Court's dismissal of "McCutcheon v. FEC" and struck down the aggregate limits. The plurality opinion invalidated only the aggregate contribution limits, not limits on giving to any one candidate or party. The decisive fifth vote for McCutcheon came from Justice Thomas, who wrote a concurring opinion stating that all contribution limits are unconstitutional.


title: Citizens United v. FEC

text: "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.


title: Citizens United v. FEC

text: After "Citizens United" and "SpeechNow.org" numerous state legislatures raised their limits on contributions to candidates and parties. At the federal level, lawmakers substantially increased contribution limits to political parties as part of the 2014 budget bill. Such changes are widely perceived as efforts to place candidates and parties on something closer to equal footing with organizations making independent expenditures.


title: Citizens United v. FEC

text: While many states and the federal government have raised contribution limits in response to "Citizens United", proposals aimed at discouraging political spending, or providing for public financing of campaigns, have been less successful.


title: Citizens United v. FEC

text: Senator Dick Durbin (D-IL) proposed that candidates who sign up small donors receive $900,000 in public money, but the proposal has not been acted on by Congress. Others proposed that laws on corporate governance be amended to assure that shareholders vote on political expenditures.


title: Citizens United v. FEC

text: In February 2010, Senator Charles E. Schumer of New York, immediate past Chairman of the Democratic Senatorial Campaign Committee, and Representative Chris Van Hollen of Maryland, Chairman of the Democratic Congressional Campaign Committee, outlined legislation aimed at undoing the decision. In April 2010, they introduced such legislation in the Senate and House, respectively. On June 24, 2010, H.R.5175 (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 U.S. companies with twenty percent or more foreign ownership, and by most government contractors. The DISCLOSE Act included exemptions to its rules given to certain special interests such as the National Rifle Association and the American Association of Retired Persons. These gaps within the proposal attracted criticism from lawmakers on both political parties. "They are auctioning off pieces of the First Amendment in this bill ... The bigger you are, the stronger you are, the less disclosure you have", said Republican Congressman Dan Lungren of California. Democratic Congressman Adam Schiff of California commented, "I wish there had been no carve-outs".


title: Citizens United v. FEC

text: The DISCLOSE Act twice failed to pass the U.S. Senate in the 111th Congress, in both instances reaching only 59 of the 60 votes required to overcome a unified Republican filibuster. A scaled down version of the DISCLOSE Act was reintroduced in both the House and Senate in 2012 but did not pass.