How the Supreme Court Could End Super PACs—Without Overturning Citizens United

In 2010, the Supreme Court opened the floodgates to money in politics with its decision in Citizens United v. Federal Elections Commission. 

The Court struck down longstanding federal restrictions on “independent” political spending by corporations and outside groups, ruling that such expenditures were protected “speech” under the First Amendment. Later that year, the D.C. Circuit Court of Appeals extended the logic of Citizens United to rule that contributions to “independent” outside...