We Don’t Need to End Citizens United to Rein in Super PACs
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By Lawrence Lessig
Published on April 28, 2026.
The author argues that the business model of American politics is corrupt and that the Supreme Court's Citizens United vs. FEC decision is not the sole reason for the creation of super PACs. He argues that super PACs have been a part of the American political scene since 2010, with many believing that this decision was the originator of super PACs. Super PACs were created by a lower federal court decision, SpeechNow v FEC, which applied the principles of Citizens United to create the super PAC. However, the author states that the court's logic, which stated that if an independent expenditure is independent, there is no risk of quid pro quo corruption, is correct. The difference between expenditures by a political committee and contributions is clearly clear, and the only regulation regulating an independent political action can be regulated. No laws could be enforced if the donor has coordinated with a candidate or its supporters, and any violation of this rule could be a constitutional violation.
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