This is the text of Article V of the US Consitution:
The Congress, whenever two thirds of both Houses shall deem it necessary, shall propose Amendments to this Constitution, or, on the Application of the Legislatures of two thirds of the several States, shall call a Convention for proposing Amendments, which, in either Case, shall be valid to all Intents and Purposes, as part of this Constitution, when ratified by the Legislatures of three fourths of the several States, or by Conventions in three fourths thereof, as the one or the other Mode of Ratification may be proposed by the Congress; Provided that no Amendment which may be made prior to the Year One thousand eight hundred and eight shall in any Manner affect the first and fourth Clauses in the Ninth Section of the first Article; and that no State, without its Consent, shall be deprived of its equal Suffrage in the Senate. [my emphasis]
Bob Reich one of my favorite economists and political commenators. Democrats were talking this way about an Article V convention in the early 1970s. But on this issue, he seems to be continuing the hiding-under-the-bed position that the Democrats have been taking for decades. The leading concern then was fear that the pro-civil rights and pro-individual freedom rulings of the Warren Court would be overturned. With the federal judiciary now dominated by Republicans, that particular concern is not one that I'd like to see Democrats cling to.
And on this issue in 2018, that Democratic attitude sounds uncomfortably like a declaration of preemptive surrender before an Article V convention is even convened. Some states have called for an Article V convention specifically on the issue of overturning Citizens United. In January 2010, in his weekly address the weekend after the Supreme Court issued that decision, Obama said, "This ruling strikes at our democracy itself. ... I can’t think of anything more devastating to the public interest." He was dead right. If the Democrats aren't even willing to use the option of pushing for an Article 5 convention over that, they are ceding a huge Constitutional option to the Republicans.
A central question is whether Congress can limit the scope of issues which an Article V convention covers. Since we've never had one, there are clear precedents based on case law on whether that is the case or not. Sara Ellis at al summarized the scholarship on the issue in "Article V Constitutional Conventions: A Primer" 78 Tennessee Law Review 663 (2011). It seems to me pretty obvious that Congress could restrict the scope of the convention.
The Democrats' expressed fear over the decades that a convention called for, say, a balanced-budget amendment (a horrible idea in itself), could rewrite any of the Constitution it chose and present those changes to be ratified. The explicit fear by the Democrats, and from liberal Republicans in the days that extinct species still existed, was that things like freedom of speech and equal voting rights were so unpopular that they would be swept away in the ratification process.
The decades-old Democratic panic over the very idea of an Article V convention ususally obscures two important features. If a convention is set up, the Democrats can play the admittedly unfamiliar politics of the convention as well or better than the Republicans can. The fight would begin with efforts in Congress to define the scope of the convention. The huge qualification is that the Dems would actually have to fight for their positions, which they have a notoriously hard time doing. Like with Obama on Citizens United.
Reich's presentation here seems to assume that an Article V convention could just set completely new rules for ratification. Amending the Constitution has to be done through the Constitutional procedures, Article V convention changes included. If an Article V convention wrote a new Consitution with a provision that it takes full effect as soon as the legislatures of, say, 11 states ratify it, there is an important historical prededent for that kind of action known as the Civil War. Though in this case the title War of the Rebellion is probably more apt.
The argument he makes seems to treat an Article V convention like ae revolutionary tool known as a Constituent Assembly. Or in this case "counter-revolutionary" for those of us who still think the American Revolution and the Delaration of Independence are fundamentally important things. Venezuela held a Constituent Assembly in 2017 that officially established a new government that the opposition and the US government refused to recognized as legitimate. Although Veneuela's arguably had far more democratic legitimation that a neo-secessionist rogue Article V convention would in the US.
That also assumes that Congress cannot or will not restrict the scope of the convention's competeence.
A rogue Article V convention rolling over the ratification procedures of the Constitution really would be a re-run of Confederate secession, as I see it. If the Trumpized Republican Party decides to give that idea a whirl, Democrats and pro-democracy Republicans - if that species hasn't followed the "moderate Republicans" into extinction - will have to fight it, of course.
But in 2018, I don't want to see the Democrats completely surrender the Article V option to the Republicans any more than they should avoid impeaching Trump because of, well, fill in the usual Democratic excuses for not fighting for their own side.
Joy Reid of MSNBC's AM Joy is a reliable defender of the Democratic establishment. Given the current mood among the party's base voters, even Establishment Democrats have to put on a convincing show of partisanship right now. If the Obama years are any measure, as soon as corporate Democrats win back the Presidency, they and their media supporters will revert to defending the weakest "bipartisan" compromises that cater to Republican conservatives as three-dimensional chess that is part of a very clever long game to someday, somehow, start achieving the sort of things that Democrats put into their official primaries.
I'll confess again to being a bit of a Mugmump on the issue of replacing Pelosi as Democratic House leader. On the one hand, it probably would be a good idea to have a Democratic leader in the House who is not so identified with the Democratic politics of the Bush and Obama Presidencies. But as Jamal Simmons observes, Pelosi by most accounts has been effective in her job as Democratic House leader.
As a national spokesperson for the Democratic Party, I've been disappointed in the lack of clarity and focus that has sometimes affected her in interviews in which she was defending Democratic positions. But that's not a problem that affected her in her weekly news briefing today, House Minority Leader Nancy Pelosi holds news briefingPBS Newshour 06/29/2017:
But she also has the huge advantage of being a literal "San Francisco Democrat" from a safely Democratic district. That was and is a welcome departure from the long-standing Democratic approach of selecting top Congressional leaders from competitive districts, apparently on the theory that their ability to appeal to swing voters would be particularly helpful. But, as Pelosi herself is shown saying in the AM Joy segment, the Republicans are going to make a boogeyman (or woman) out of any Democratic leader. The Republicans just don't share the Democrats chronic desire to pursue "bipartisanship." Charlie Pierce gives his take on Pelosi's leadership in Okay, So You Kick Nancy Pelosi Out. Then What?Esquire Politics Blog 06/21/2017.
Joy begins the segment by calling Democrats who advocate a new House leader "haters and critics." She sets the segment up on the premise that Republicans demonized Pelosi's image, and now (progressive) Democrats have been naively suckered into carrying water for the Republicans' anti-Pelosi position. Joy cites as a major example of Pelosi's value to the Democrats the fact that she appointed Rahm Emmanuel to lead the DCCC (Democratic Congressional Campaign Committee) during the 2006 eleciton cycle. Rahm is the poster-boy for the corporate Dem position, famously telling advocates of the public option for health care in 2009 that they were "f***ing retarded." (Was Rahm Right?In These Times 04/06/2011) Ryan Lizza wrote about interviewing Rahm in his office when he was Obama's first White House Chief of Staff, "I noticed that over his left shoulder, on the credenza behind him, was an official-looking name plate, which he said was a birthday present from his two brothers. It read, 'Undersecretary for Go Fuck Yourself.'" (The GatekeeperNew Yorker 03/02/2009).
As a sideline, I would note that if the ACA (Obamacare) had included the public option that most Democrats wanted and which Rahm so memorably condemned, it would almost certainly have been more popular than it clearly is now, less vulnerable to Republican Governors' sabotage, and more durable in the face of the current Republican efforts to repeal it. Although I'm relieved and a bit pleasantly surprised as how durable it's turning out to be in the first half of 2017.
The AM Joy segment features four guests: former RNC Chair Michael Steele, Nation journalist Joan Walsh, actor-commentator Jamal Simmons and Roll Call's Michele Bernard. Three of the four join with the host in ridiculing the idea of Democrats replacing Pelosi as the House leader. Joy doesn't probe Michael Steele's dubious-sounding claim to be a master of strategic branding who fought successfully against other Republicans to make Pelosi a major image of the Democratic Party. He even says he got them to focus on making Pelosi the main target of their attacks instead of Barack Obama. (Say what?!)
Simmons mentions vaguely that the Democrats need a stronger identification with economic issues. None of the panel, including Joy herself, gives much attention in this segment to the substantive criticism that some progressives have made, not least of which is that she's too much a part of the corporate-financed model of politics that has metastasized since the Citizens United decision in 2010.
Joan Walsh, after 10:00, says:
The whole battle in the party right now, which is a false battle in my opinion, but it's there, between 'identity politics' - so-called - and class politics, that's being fought here too, but in ways that people won't say. Because Pelosi is a associated with gay marriage, being from San Francisco, but also being staunchly for it. She's associated with feminism. She's associated with these things that certain elements of the party think should be downplayed to appeal to white men, white, you know, rather than focusing on the base of our party, which is women, and particularly women of color.
I often quote Joan's analysis, usually with approval. But that particularly comment is one that bothers me. In fairness, her target isn't entirely clear in the brief time she had to speak. The segment featured criticism of Pelosi from Ohio Congressman Tim Ryan, who unsuccessfully challenged her in the House for her leadership position. And Ryan has stressed a particular approach to criticizing Pelosi.
Ryan, who describes himself as “feisty,” has turned more aggressive in recent days. Though Ryan has criticized the party for prioritizing appeals to “subgroups” over a central economic message, his volleys against Pelosi veer close to an identity politics of his own—Make the Democrats Great Again—that relies on hackneyed imagery such as the beer drinker on Steel Street. “This election’s not going to be won at fundraisers on the coasts,” he told the Wall Street Journal, “it’s going to be won in union halls in the industrial Midwest and fish fries in the Midwest and the South.” Ryan also told me that his relative youth would serve the party well with millennials. (Ryan, 43, is not a millennial.)
The “union hall” thing did not sit well with Pelosi. “I’m not going to pay attention to, ‘I can’t step in a union hall.’ I’m a woman of steel in there,” Pelosi told the Huffington Post on Tuesday. “I’m constantly invited by the unions to go to their meetings. That’s just not, it’s just not true.” She also mocked Ryan for not being able to carry his district for Hillary Clinton, and she described his complaint that her proposed internal reforms would only strengthen her grip over the caucus as “pathetic.”
Back circa 1990, the major ideological fault line in the Democratic Party was understood to between traditional liberals of the Ted Kennedy/Walter Mondale mode and Democratic Leadership Council (DLC) that embraced neoliberal economics and hedged on "social issues" like abortion and even anti-discrimination issues. Bill Clinton was the embodiment of that approach. Any such broad distinction is inevitably oversimplified. The Republican were more than happy to portray Clinton as a flaming leftwing radical who was a wimp in foreign policy. And the labor movement nad the most prolabor Members of Congress were the bedrock of the defense of Clinton in the impeachment fight. Most DLC types didn't go as far off the tracks as Joe Lieberman eventually did. In fact, even the DLC got sick of Lieberman's antics sabotaging the Democrats before he left the Senate. On the other hand, the Democrats were all too eager to welcome Lieberman back into the Democratic Caucus after he actively campaigned for John McCain in the 2008 Presidential contest.
That traditional liberal/DLC-Blue Dog split among Dems doesn't describe the current major ideological fault line in the Democratic Party, which crystallized in 2016 in the Bernie-vs.-Hillary divide. At the moment, we can broadly describe the Bernie wing of the party as explicitly social-democratic, even militantly so. It's an outlook that openly embraces the spirit and content of the New Deal in a way even the liberal wing of 1990 was somewhat hesitant to do. On social issues, the Bernie wing is very much in favor of strong enforcement of anti-discrimination laws for racial minorities, women and the LGBTQ community. And supportive of a humane immigration reform that gives a straightforward path of citizenship to the millions of mostly Latino undocumented immigrants in the US. And though the foreign policy position of the Bernie wing may not be quite so consistent as on economic and social issues, it's broadly speaking a peace-oriented view with a healthy skepticism of US military interventions. And for the New Deal wing, campaign reform that's definitively overturns Citizens United is a major priority. Because, as Barack Obama himself said of the decision when it was first handed down:
This ruling strikes at our democracy itself.
This ruling opens the floodgates for an unlimited amount of special interest money into our democracy. It gives the special interest lobbyists new leverage to spend millions on advertising to persuade elected officials to vote their way – or to punish those who don’t. That means that any public servant who has the courage to stand up to the special interests and stand up for the American people can find himself or herself under assault come election time. Even foreign corporations may now get into the act.
I can’t think of anything more devastating to the public interest.
Unfortunately, Obama's sense of urgency proved to be relatively short-lived. But the New Deal Democrats tend to take those sentiments very seriously, even if Obama may not have.
In retrospect, Jerry Brown's Presidential campaign in 1992 was an early version of today's New Deal Democratic position, supportive of labor, minority rights, women's rights and immigrants, in favor of single-payer health care, and giving a central emphasis to reducing the role of money in politics. And that was 18 years before Citizens United! He was also in favor of a peace-oriented foreign policy that would take maximum advantage of the opportunites prsented by the fall of the Warsaw Pact and the Soviet Union.
Today's corporate Democrats are not worrying about "Sister Soljah moments" or opposing same-sex marriage. On the contrary, they are straightforwardly in favor of women's rights and gay rights and minority rights. But they support neoliberal economic policies: deregulation, privatization (charter schools, private prisons, etc.), low taxes for the wealthy, international agreements to dergulate capital and corporations masquerading as trade treaties, praising of balanced budgets as an excuse to forgo Keynesian economic stimulus. They are also distinctly hawkish in foreign policy, though they typically rely more on "liberal internationalist" rhetoric than Cheney style neoconservative framing, though in practice they often come to the same thing. And they are comfortable with corporate-financed elections and supportive of them, despite ritual denunciations of Citizens United. Barack Obama and Hillary Clinton are outstanding current example of the corporate Democratic camp.
In this context, Joan Walsh's comment struck me. It almost sounded like she was identifying the New Deal/Bernie Sanders wing with the old DLC approach as though they were opposing minority and women's rights.
The reality is more that the corporate Dems emphasize those issues as a way to avoid advocating aggressively for prolabor economic policies.
I don't have anything particularly insightful to say about the outcome of the Presidential election. Because I assume it's obvious to everyone that in two months, the inmates will officially take charge of the asylum.
But I do know the incoming President made it a central campaign promise to deport all undocumented immigrants. Like on most everything, he was vague and sometimes self-contradictory on that. But he did promise that he would make a two-year push to deport them all. He explicitly referred to the deportation program under President Eisenhower, which was literally called Operation Wetback. It was a brutal operation that directly resulted in numerous deaths. And that was under Dwight Eisenhower, who in Republican terms then was considered a moderate or even a liberal.
That also involved about two million people forced out of the country. Today it is commonly estimated that there are 11-12 million, playing a far more significant role in the economy. American agriculture is almost completely dependent on *undocumented* labor. I've seen one historian claim that expelling 12 million people would be the largest forced migration in all of history. I don't know how it may rank in the Guiness Book of Humanitarian Horrors. But it would involve a lot of very real horror. Trump very recently promised that immediately after inauguration he would deport 2 million "criminal" immigrants.
Donald Trump fue electo presidente de los Estados Unidos de América, sobre una plataforma que incluyó la promesa de deportaciones masivas, la construcción de un gran muro entre Estados Unidos y México y el reforzamiento del sistema policial fronterizo, triplicando la cantidad de agentes de inmigración y anulando medidas ejecutivas de ayuda a los inmigrantes.
[Donald Trump was elected President of the United States of America on a platform that included the promise of massive deportations, the construction of a big wall between the United States and Mexico and the reinforcing of the frontier police system, tripling the number of immigration agents and annuling executives measures to support immigrants.]
And she writes, "los grupos que por años han luchado contra las deportaciones y la militarización de la frontera, y por una reforma migratoria, buscan reagruparse y comenzar una lucha que se presenta titánica" ("the groups who have been fighting for years against deportations and the militarization of the frontier, and for immigration reform, are seeking to regroup and to begin a fight that appears to be titanic").
There is also the very real effect of systematic, segregationist voter-suppression efforts targeting especially black and Latino voters. Rick Perlstein summed up the state of play on those recently in GOP Voting Fraud Squads Are Nothing NewWashington Spectator 11/04/2016.
As journalist Ari Berman, who covers the voting rights beat, pointed out today, this is the first presidential election in half a century without the full protections of the Voting Rights Act. The 2013 Supreme Court ruling Shelby County v. Holder invalidated federal oversight of states with a history of voting discrimination.
But quantifying exactly how much the changes have depressed turnout is nearly impossible.
“It’s exceedingly difficult to measure the effects of voter ID laws,” says David Becker, the executive director of the Center for Election Innovation & Research. That’s because, Becker notes, “it’s incredibly hard to know who’s choosing not to vote because of barriers.”
But "not easy" is far from meaning "impossible." There are ways to determine the effects of voter suppression, as the Justice Department did in the early 1960s in court challenging segregationist voter suppression laws then.
Ari Berman, who is quoted there, has been doing great work reporting on this nefarious practice in its various forms. He explained in a piece in May the stakes involved, Voter Suppression Is the Only Way Donald Trump Can WinThe Nation/Moyers & Company 05/10/2016:
Unless there’s an unexpected turnaround in his terrible numbers among nonwhite and young voters, there’s only one way Trump can win the general election: by massively suppressing Democratic voters or hoping they don’t show up on Election Day. Trump could do this by supporting new voting restrictions adopted by GOP-controlled states (17 have new restrictions in place for the first time in 2016), urging his supporters to create chaos at the polls and running a breathtakingly negative campaign that demobilizes his opposition.
Trump’s support in the primary directly correlated with racial resentment toward African-Americans, Hispanics and Muslims. “The higher you scored on racial resentment, the more likely you were to support Trump; the more you resented immigrants or professed your white ethnocentrism, the likelier you were to plan to vote for Trump,” wrote Tom Edsall in The New York Times. It’s not a stretch to imagine Trump supporters trying to block these same voters from the polls.
We probably won't have a decent picture of how that worked in yesterday's election for a while. As Ari noted there, "Studies have shown that restrictions like voter-ID laws can reduce voter turnout by 2 to 3 percent, with the largest drop-off among young, first-time and African-American voters."
Then there is campaign-financing system, which the Republican-dominated Supreme Court made orders of magnitude worse with their Citizens United decision. I wrote just after that decision in 2010:
But this week, the United States Supreme Court handed a huge victory to the special interests and their lobbyists – and a powerful blow to our efforts to rein in corporate influence. This ruling strikes at our democracy itself. [my emphasis]
This ruling opens the floodgates for an unlimited amount of special interest money into our democracy. It gives the special interest lobbyists new leverage to spend millions on advertising to persuade elected officials to vote their way – or to punish those who don’t. That means that any public servant who has the courage to stand up to the special interests and stand up for the American people can find himself or herself under assault come election time. Even foreign corporations may now get into the act.
I can’t think of anything more devastating to the public interest. The last thing we need to do is hand more influence to the lobbyists in Washington, or more power to the special interests to tip the outcome of elections. [my emphasis]
But will he fight for real solutions? Sadly, he pleaded for a "bipartisan" solution, which has become for the Obama administration and the current Senate leadership at least an offer of preemptive surrender.
We currently have one Party, the Republicans, who are both strongly partisan and willing to fight for their goals. We have another Party, the Democrats, who are lukewarm partisan and not notably willing to fight for the goals that are most important to their Party's own base and to the majority of the people.
Sadly, the Party that is made up of fighting partisans has also become an authoritarian Party hostile to democracy and the rule. (See Bush v. Gore, the Cheney-Bush torture policy, to take two examples among many.)
It really is remarkable for the President of the United States to say of a Supreme Court decision:
This ruling strikes at our democracy itself.
I can’t think of anything more devastating to the public interest.
But those words at this particular moment in time remind me of what's been so gut-wrenching disappointing to even Democrats like me, who never viewed Obama as some kind of democratic messiah. His actions haven't matched up to the urgency of his words.
There will be a lot to say about the 2016 election. For a long time. But this are some of the most urgent issues that stand out for me on the morning after.
Among the many news reports on the Supreme Court's decision to open the floodgates even widen to corporate money in elections, this is a good one from the Los Angeles Times, Supreme Court OKs unlimited corporate spending on elections by David Savage 01/22/10. The LA Times editorial on the decision, The 1st Amendment and corporate campaigning 01/22/10, while supporting the Court's position on the narrow issue that was before it, explains that this was a piece of aggressive judicial activism that went far beyond the narrow scope of the case to reverse a century of Constitutional law. This was really a radical right decision.
But this week, the United States Supreme Court handed a huge victory to the special interests and their lobbyists – and a powerful blow to our efforts to rein in corporate influence. This ruling strikes at our democracy itself. [my emphasis]
This ruling opens the floodgates for an unlimited amount of special interest money into our democracy. It gives the special interest lobbyists new leverage to spend millions on advertising to persuade elected officials to vote their way – or to punish those who don’t. That means that any public servant who has the courage to stand up to the special interests and stand up for the American people can find himself or herself under assault come election time. Even foreign corporations may now get into the act.
I can’t think of anything more devastating to the public interest. The last thing we need to do is hand more influence to the lobbyists in Washington, or more power to the special interests to tip the outcome of elections. [my emphasis]
But will he fight for real solutions? Sadly, he pleaded for a "bipartisan" solution, which has become for the Obama administration and the current Senate leadership at least an offer of preemptive surrender.
We currently have one Party, the Republicans, who are both strongly partisan and willing to fight for their goals. We have another Party, the Democrats, who are lukewarm partisan and not notably willing to fight for the goals that are most important to their Party's own base and to the majority of the people.
Sadly, the Party that is made up of fighting partisans has also become an authoritarian Party hostile to democracy and the rule. (See Bush v. Gore, the Cheney-Bush torture policy, to take two examples among many.)
It really is remarkable for the President of the United States to say of a Supreme Court decision:
This ruling strikes at our democracy itself.
I can’t think of anything more devastating to the public interest.
But those words at this particular moment in time remind me of what's been so gut-wrenching disappointing to even Democrats like me, who never viewed Obama as some kind of democratic messiah. His actions haven't matched up to the urgency of his words.
The plain meaning of those words is that our entire democratic and Constitutional system is at serious and grave risk as a result of the Supreme Court's ruling in Citizens United v. FEC. And this isn't some radio or FOX News demagogue saying this. It's the President of the United States and the head of the Democratic Party. Those words describe a danger that requires immediate remedies, now, this year, 2010, while the Democrats have a large majority in both Houses and the Presidency. Those words call for dragging or driving the Blue Dogs and the merely intimidated among the Democratic Members of Congress into acting.
But democracy and the rule of law is also under grave risk from the Cheney-Bush torture policy and massive domestic surveillance. And the Obama administration refuses to prosecute perpetrators from those programs and endorses much of the underlying legal defenses for both, which completely embracing the surveillance policy with the explicit approval of Congress.
So what is the President actually proposing on this new threat to democracy and the Constitution, this Court decision of which he "can’t think of anything more devastating to the public interest"? So far, something about on the same level of uselessness as a typical commission study: "When this ruling came down, I instructed my administration to get to work immediately with Members of Congress willing to fight for the American people to develop a forceful, bipartisan response to this decision."
Yeah, let's appoint at bipartisan commission to study the problem for a couple of years. Maybe Joe Lieberman and John McCain can co-chair it. Let's show bipartisan goodwill by putting Michelle Bachman and James Baker on the commission. They can study the problem for a couple of years and then deadlock along partisan lines. Historians chronicling the final years of American democracy will be able to consult the majority and minority reports of the commission as they draw the reasoned conclusion that the President was right: "This ruling strikes at our democracy itself."
There are some constructive things that can be done, none of them involving the intervention of the Bipartisan Holy Grail that the Democrats continue to invoke as their excuse for failing. Congress can require corporations to get approval from 99% of their stockholders, for instance, before spending shareholders' money on political campaigns. They could impose high disclosure requirements along the lines of, "This ad was authorized by Daddy Warbucks, CEO of Predator Bank, which stands to make billions of additional profit if Congress does what this ad advocates." They could restrict business activities by corporations that run political ads, or deny them government contracts. Not all of this would necessarily stand up to Republican Supreme Court review. But part of the way to fight these things is for the elected representatives in Congress to assert their legislative intent forcefully in restricting the ability of corporations to corrupt elections. Congress could even change the laws of incorporation to knock out the legal position, which was bad law from its beginnings in the 19th century, that corporations are legally equivalent to individuals, which is part of the basis of the Citizens United decision.
Since this ruling also reduces restraints on union political activity, this is yet another incentive for the Democrats to pass the Employee Free Choice Act to facilitate union organizing. This is a critical way to build up countervailing social power against corporate dominance.
There's also the Constitutional Amendment option but the Republicans will fight that tooth and nail, including with bundles of corporate political spending that the Court has now unleashed, so that's not a short-term solution.
Green Greenwald, a civil liberties hardliner, finds aspects of the decision to like but also declares himself "deeply ambivalent" on the ruling: What the Supreme Court got rightSalon 01/22/10; and, Follow-up on the Citizens United case 01/23/10. Glenn underestimates how much this ruling can expand corporate domination of politics. He does make some interesting points about how the notion of corporations as persons figured into this case.
Heather Gerken, The Real Problem with Citizens UnitedThe American Prospect 01/22/10. She points out that the Citizens United ruling may have even broader implications for anti-corruption laws than just political advertising.
