[EL] "Citizens United poised to destroy judicial impartiality"

[Benjamin Barr]

You're missing the point, Mark.

They don't want to support candidates.  They'd like to speak about issues
closely tied to candidates.  Government and bureaucratic overseers believe
they can divine the intent of these groups and the "true purpose" of their
advocacy.  The groups don't think they need to register with the government
or hire scores of expensive cartel members to exercise First Amendment
freedoms.

The burden created is ambiguous standards to determine who's in and who's
out of the regulatory bucket and overbroad application of PAC rules to
groups that don't intend to oppose or support candidates.  Those burdens
come from government, as do the ensuing financial costs.  Even those of
modest means have full First Amendment rights.

The question is not "are there other less attractive means to speak," but
"is the manner in which they'd like to speak freely open to them without
undue government interference?"  That government "leaves open 'more
burdensome' avenues of communication, does not relieve its burden on First
Amendment expression."  Meyer v. Grant (citing, yes, MCFL).  That's settled
law, too.

Then there's a question of group autonomy and self-direction.  Why should I
be forced to join the NRA if I don't like it?  Why can't I make my own
group, absent piles of government burdens, to express my distinct views
with my friends?  Why are people of modest means limited to only joining
and supporting the tired parade of the status quo?  Why should my coffee
clutch have to register with the federal government and declare its "major
purpose" is the nomination or defeat of candidates when it is not?  The
ACLU has made this argument before, as has the Chamber, and numerous other
groups.

Burdens come from government schemes to filter, purify, and cleanse the
political process.  That these misguided efforts hit those of modest means
most severely should suggest their swift eradication.  Here's hoping so!

Forward,

Ben




On Mon, Aug 5, 2013 at 3:17 PM, Mark Schmitt <schmitt.mark at gmail.com> wrote:
>
> If the principle is that people of ordinary means should be able to, as
Joe LaRue put it, "pool my money with others to support a candidate whose
ideas I like", then why is the appropriate measure of a burden on that
expression the difficulty of creating a new PAC or new corporation?
Shouldn't the question be, whether for an individual, there exists a
reasonable mechanism to join with others to support such a candidate?  In
my experience, there are usually quite a few ways to do that.  There is, of
course, the $5200 (primary and general) that you can pool in hard money,
which as I learned when a close relative ran for Congress last year and I
actually felt obliged to max out, is really quite a bit of money for an
ordinary household. (It was my family's largest single expenditure of the
year, on anything.) In addition, there are generally numerous other
established PACs or other committees through which one can support one or
more candidates, as well as countless opportunities to support candidates
that emphasize particular issues, e.g. Club for Growth or League of
Conservation Voters. That was the case both before and after CU and
SpeechNow. "People of modest means" have no shortage of channels through
which they can join to support candidates.
>
> The burden on the political speech of "people of modest means" is their
modest means, not the paperwork hurdles of starting their own PAC.
>
>
> Mark Schmitt
> Senior Fellow, The Roosevelt Institute
> 202/246-2350
> gchat or Skype: schmitt.mark
> twitter: mschmitt9
>
>
> On Mon, Aug 5, 2013 at 2:12 PM, Benjamin Barr <benjamin.barr at gmail.com>
wrote:
>>
>> What's more, last I checked the electric company didn't:
>>
>> Examine whether your little greenhouse might constitute the "functional
equivalent" of electricity and turn your "major purpose" into electricity
production;
>> Change its billing practices on a month-to-month or customer-to-customer
basis based on factors like "proximity of customer to the electron's nexus";
>> Demand that you hire scores of attorneys and accountants to figure out
obscure electricity pricing practices known only by a few dozen members of
a select cartel;
>> Use the coercive power of the state to launch civil or criminal
investigations;
>> Haul you before it for investigatory purposes with few basic
constitutional rights recognized;
>> Or otherwise set up convoluted barriers to exercising a fundamental
liberty.
>>
>>
>> Forward,
>>
>> Ben
>>
>>
>>
>>
>> On Mon, Aug 5, 2013 at 1:58 PM, Steve Klein <stephen.klein.esq at gmail.com>
wrote:
>>>
>>> Joe,
>>>
>>> I think it's worth considering that it's not just each step of PAC
(etc.) compliance that burdens political speech, but the fact that one
wrong move can result in civil penalties. The alternative between paying
attorney and/or accountant fees for compliance versus risking penalties
when one tries it with no expertise does not strike me as friendly toward
grassroots participation.
>>>
>>> Unlike paying the power bill, this is political speech we're talking
about. It should be just as easy to engage than to actually vote in a
federal election.
>>>
>>> Steve
>>>
>>>
>>> On Mon, Aug 5, 2013 at 11:37 AM, Joseph Birkenstock <
jbirkenstock at capdale.com> wrote:
>>>>
>>>> True story: I had a law school roommate (great guy, this was our third
year of law school and we’re all still close friends to this day) who came
to me and our other roommate one time to complain that we had unfairly
divided up the household chores.  Roommate A felt overburdened, he
explained, because in addition to doing a full share of kitchen-cleaning
and trash-taking-out and so forth, he was also responsible for “paying the
power bill.”
>>>>
>>>>
>>>>
>>>> Roommate C & I looked at each other kind of quizzically at this point,
since we divided up all the utilities three ways and we each paid a third.
 So Roommate A went on to explain that while we did all in fact pay the
same share in dollars, only he was responsible for (and I’m pretty sure I
can recall this quote verbatim): “Picking up the checks, stuffing the
envelope, putting a stamp on the envelope, putting it in the mail, etc.”
>>>>
>>>>
>>>>
>>>> We all had a lot of fun with that “etc.” in particular over the years,
since regardless of the serious threats Roommate A faced from paper cuts
and the like in steps one through three, we’re all pretty sure that there’s
actually nothing else involved in paying the power bill once you’ve put it
in the mail.  And in sum, no matter how you count the steps, physically
paying the power bill is in fact pretty trivially easy.
>>>>
>>>>
>>>>
>>>> Even easier than running a PAC.
>>>>
>>>>
>>>>
>>>> Best,
>>>>
>>>> Joe
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> From: Benjamin Barr [mailto:benjamin.barr at gmail.com]
>>>> Sent: Monday, August 05, 2013 1:27 PM
>>>> To: Joseph Birkenstock
>>>> Cc: Brad Smith; Jim Bopp; Salvador Peralta; law-election at uci.edu;
joseph.e.larue at gmail.com; adam at boninlaw.com
>>>>
>>>>
>>>> Subject: Re: [EL] "Citizens United poised to destroy judicial
impartiality"
>>>>
>>>>
>>>>
>>>> On that point, MCFL lists some 23 burdens related to PAC status. CU
eliminates two (corporate prohibition and solicitation). Speechnow removes
one more ($5000 limit). I still count twenty burdens (perpetual reporting,
accounting and banking methods, detailed disbursements in 12 categories,
and so on). Seems like an effective speech gag for most Americans of
moderate means.
>>>>
>>>> And then again , CU actually says that even if PACs somehow resolved
the corporate ban issue , they're still burdensome as a matter of law
because they're so difficult to set up and administer. Doesn't seem like
there's much wiggle room around that.
>>>>
>>>> Forward,
>>>>
>>>> Ben
>>>>
>>>> Sent by my Android device. Please excuse any typographical errors.
>>>>
>>>> On Aug 5, 2013 1:13 PM, "Joseph Birkenstock" <jbirkenstock at capdale.com>
wrote:
>>>>
>>>> On the point about the ease of pursing the PAC option: I think it’s
worth bearing in mind how much those burdens have changed in recent years.
 Before Speechnow v. FEC (i.e., under the law at the time Citizens United
was litigated), becoming a federal PAC meant complying with a $5,000 per
calendar year limit on each individual’s contributions, and sharing that
side of each donor’s biennial aggregate limit with every other federal PAC
& party committee.  In many states and localities, even IE-only PACs still
face at least stated interpretations from regulators that their donors are
still subject to respective state or local PAC contribution limits.
>>>>
>>>>
>>>>
>>>> I don’t disagree that opponents of campaign finance regulation
continue to greatly overstate the burdens of creating a PAC (especially, as
Adam also points out, compared to the burdens of creating a corporation),
but too many proponents of campaign finance regulation greatly understated
those burdens for a long time too.
>>>>
>>>>
>>>>
>>>> Best,
>>>>
>>>> Joe
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> ________________________________
>>>> Joseph M. Birkenstock, Esq.
>>>> Caplin & Drysdale, Chtd.
>>>> One Thomas Circle, NW
>>>> Washington, DC 20005
>>>> (202) 862-7836
>>>> www.capdale.com/jbirkenstock
>>>> *also admitted to practice in CA
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> From: law-election-bounces at department-lists.uci.edu [mailto:
law-election-bounces at department-lists.uci.edu] On Behalf Of Salvador Peralta
>>>> Sent: Monday, August 05, 2013 1:01 PM
>>>> To: JBoppjr at aol.com; adam at boninlaw.com; joseph.e.larue at gmail.com
>>>> Cc: law-election at uci.edu; BSmith at law.capital.edu
>>>> Subject: Re: [EL] "Citizens United poised to destroy judicial
impartiality"
>>>>
>>>>
>>>>
>>>> As Adam points out, Jim's argument about the "difficulties in setting
up a pac" relative to a corporation is questionable at best.  In practical
terms, the main reason to use a corporation rather than a pac is to avoid
disclosure of the actual funding sources, not because PAC's are
particularly difficult to set up.
>>>>
>>>> Regarding Jim's false assertion that most reformers want people of
"average means" to spend zero on Independent Expenditures..."  It's a
strange argument, given the fact that Jim has the distinction of doing more
than just about anyone in our nation's history to ensure that, as a
percentage of total spending, people of average means have much less of an
ability to influence elections through financial contributions (through
IE's or anything else).
>>>>
>>>> In 2012, as a percentage of total super pac spending, the amount spent
by people of limited means (read:  Anyone who can't afford to spend at
least $1,000) is well nigh to zero.
>>>>
>>>> The data may not track exactly to "people of ordinary means", but as
the link I sent earlier in the week shows, 98% of the money spent on Super
Pac IE's in 2012 came from the approximately 2,800 donors who spent more
than $10,000 and 60% came from donors who spent at least $1,000,000.
>>>>
>>>>
http://www.demos.org/publication/election-spending-2012-post-election-analysis-federal-election-commission-data?key=0
>>>>
>>>> Out to protect the "little guy" indeed.
>>>>
>>>> Best regards,
>>>>
>>>> Sal Peralta
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> ________________________________
>>>>
>>>> From: "JBoppjr at aol.com" <JBoppjr at aol.com>
>>>> To: adam at boninlaw.com; oregon.properties at yahoo.com;
joseph.e.larue at gmail.com
>>>> Cc: law-election at uci.edu; BSmith at law.capital.edu
>>>> Sent: Monday, August 5, 2013 4:30 AM
>>>> Subject: Re: [EL] "Citizens United poised to destroy judicial
impartiality"
>>>>
>>>>
>>>>
>>>> If the reformers had their way, it would be zero.  Jim Bopp
>>>>
>>>>
>>>>
>>>> In a message dated 8/4/2013 8:50:20 A.M. Eastern Daylight Time,
adam at boninlaw.com writes:
>>>>
>>>> Which is all interesting analysis if the corporation already exists,
but not if it doesn’t – a PAC doesn’t require by-laws or articles of
incorporation; it doesn’t have to publish its existence in classified ads
in newspapers of sufficient circulation; its tax obligations are much
easier to deal with; it does not have to have a board of directors required
to meet regularly and take minutes; etc.
>>>>
>>>>
>>>>
>>>> Exactly what percentage of independent expenditures during the 2012
election were funded by “people of average means”?
>>>>
>>>>
>>>>
>>>> From: JBoppjr at aol.com [mailto:JBoppjr at aol.com]
>>>> Sent: Sunday, August 04, 2013 8:41 AM
>>>> To: adam at boninlaw.com; oregon.properties at yahoo.com;
joseph.e.larue at gmail.com
>>>> Cc: law-election at uci.edu; BSmith at law.capital.edu
>>>> Subject: Re: [EL] "Citizens United poised to destroy judicial
impartiality"
>>>>
>>>>
>>>>
>>>> Requiring political speech to be done through a PAC creates, as the
Court in Citizens United explained, a substantial burden on speech.  As a
result, there are only a few thousand corporate PACs but millions of
corporations.  Only the most wealthy and sophisticated corporations have
the wherewithall to and interest in negotiating these burdens, so again the
PAC requirement favors the wealthy and disenfranchises the rest of us.  Jim
Bopp
>>>>
>>>>
>>>>
>>>> In a message dated 8/4/2013 8:24:12 A.M. Eastern Daylight Time,
adam at boninlaw.com writes:
>>>>
>>>> Fine, I’ll bite: what about PACs?  If we’re only talking about people
of average means, and not the 0.26% of citizens who’ve given more than $200
to a congressional candidate (or 0.05% who’ve given a maximum
contribution), why weren’t PACs already a sufficient answer to the problem
you claim existed?
>>>>
>>>>
>>>>
>>>> From: law-election-bounces at department-lists.uci.edu [mailto:
law-election-bounces at department-lists.uci.edu] On Behalf Of JBoppjr at aol.com
>>>> Sent: Sunday, August 04, 2013 7:41 AM
>>>> To: oregon.properties at yahoo.com; joseph.e.larue at gmail.com
>>>> Cc: law-election at uci.edu; BSmith at law.capital.edu
>>>> Subject: Re: [EL] "Citizens United poised to destroy judicial
impartiality"
>>>>
>>>>
>>>>
>>>>     Mr. Oregon.Properties, rather than accuse Joe of being
disingenuous, try for a second to substantively address his point.
>>>>
>>>>
>>>>
>>>>     I summarize: Rich people can spend their own money but people of
average means need to pool their resources to compete.  They do so in labor
unions and corporations.  So when you limit labor unions and corporations,
you are targeting the only vehicle that people of average means have, and
not the wealthy, who can always spend their own money without limitation.
>>>>
>>>>
>>>>
>>>>     No wonder George Soros and the wealthiest foundations fund the
"reform" industry.  Jim Bopp
>>>>
>>>>
>>>>
>>>> In a message dated 8/4/2013 3:08:43 A.M. Eastern Daylight Time,
oregon.properties at yahoo.com writes:
>>>>
>>>> Joe - Do you have to practice in front of a mirror to keep a straight
face when you say things like that?
>>>>
>>>>
>>>>
http://www.demos.org/publication/election-spending-2012-post-election-analysis-federal-election-commission-data?key=0
>>>>
>>>>
>>>>
>>>> Sent from my iPhone
>>>>
>>>>
>>>> On Aug 3, 2013, at 4:47 PM, Joe La Rue <joseph.e.larue at gmail.com>
wrote:
>>>>
>>>> The point of CU was to give people of modest means like me the
opportunity to join with other people of modest means and compete with the
George Soroses of the world. I can't compete with him otherwise. Remember
he can spend as much of his own money as he wants. The only chance a little
guy like me has is to associate with other people and pool our money. CU
was not about benefiting the powerful. It was about the right to freely
associate and do as an association what rich people like George Soros can
do by themselves.
>>>>
>>>>
>>>> On Aug 3, 2013, at 7:15 PM, Sal Peralta <oregon.properties at yahoo.com>
wrote:
>>>>
>>>> I have not seen anyone suggest that legislating the content or number
of add is appropriate -- though many swing state voters might appreciate
it.  It seems to me that the nut of the judge's argument takes aim at the
legal fiction that IE's supporting a candidate or tearing down their
opponent cannot lead to undue influence.  But I guess giving more influence
to the powerful was also "sort of the point" of CU.
>>>>
>>>> Sent from my iPad
>>>>
>>>>
>>>> On Aug 3, 2013, at 9:56 AM, Sal Peralta <oregon.properties at yahoo.com>
wrote:
>>>>
>>>> http://mediaproject.wesleyan.edu/2012/05/02/jump-in-negativity/
>>>>
>>>> Sent from my iPhone
>>>>
>>>>
>>>> On Aug 3, 2013, at 9:46 AM, "Smith, Brad" <BSmith at law.capital.edu>
wrote:
>>>>
>>>> Isn't the better comparison a negative "issue ad" to a negative
"express advocacy" ad, and a positive to a positive?
>>>>
>>>>
>>>>
>>>> Is there any evidence that a higher percentage of ads post-CU are
negative, or if so, that this is because of CU?
>>>>
>>>>
>>>>
>>>> To the extent we simply see more ads, well, that was sort of the point
of CU and SpeechNow. If one is arguing that we should try to legislate
fewer ads, doesn't that reveal that the real purpose is directly to limit
the quantity of speech?
>>>>
>>>>
>>>>
>>>> And again, none of this accounts for the fact that in a majority of
states, pre-CU, corporations could pay for express ads, so to bring it back
to my original post, I remain baffled why so many predictions of CU are
made with no recognition for what the law, and was the results were, pre-CU.
>>>>
>>>>
>>>>
>>>> Bradley A. Smith
>>>>
>>>> Josiah H. Blackmore II/Shirley M. Nault
>>>>
>>>>    Professor of Law
>>>>
>>>> Capital University Law School
>>>>
>>>> 303 E. Broad St.
>>>>
>>>> Columbus, OH 43215
>>>>
>>>> 614.236.6317
>>>>
>>>> http://law.capital.edu/faculty/bios/bsmith.aspx
>>>>
>>>> ________________________________
>>>>
>>>> From: Trevor Potter [tpotter at capdale.com]
>>>> Sent: Saturday, August 03, 2013 3:10 PM
>>>> To: Adam Bonin
>>>> Cc: Smith, Brad; law-election at UCI.edu
>>>> Subject: Re: [EL] "Citizens United poised to destroy judicial
impartiality"
>>>>
>>>> Of course, political consultants will tell us that a "thank you"
"issue ad" is not as effective as a full- throated negative express
advocacy commercial-- which is no doubt why we see more of the latter post-
Citizens United in states that prohibited corporate funded IEs-- like
Montana.
>>>>
>>>>
>>>>
>>>> Trevor Potter
>>>>
>>>> Sent from my iPhone
>>>>
>>>>
>>>> On Aug 3, 2013, at 12:38 PM, "Adam Bonin" <adam at boninlaw.com> wrote:
>>>>
>>>> Perhaps my favorite such example: $1.2M in corporate-funded ads aired
in the final week of Pennsylvania’s 2007 election cycle encouraging voters
to “thank” Judge Maureen Lally-Green, who happened to be on the ballot for
the Supreme Court. (Pre-CU, and PA did not allow corporate contributions or
independent expenditures at the time.)  Not only did efforts to enjoin the
ads fail (because the ads contained no express advocacy), but the
Commonwealth was ordered to reimburse the sponsor for its legal fees, and
the sponsor was not required to register as a political committee.
>>>>
>>>>
>>>>
>>>> http://www.youtube.com/watch?v=bnifj2A7Has
>>>>
>>>>
http://articles.philly.com/2008-05-07/news/24989915_1_corbett-spokesman-kevin-harley-ads-political-expenditures
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> Adam C. Bonin
>>>> The Law Office of Adam C. Bonin
>>>> 1900 Market Street, 4th Floor
>>>> Philadelphia, PA 19103
>>>> (215) 864-8002 (w)
>>>> (215) 701-2321 (f)
>>>> (267) 242-5014 (c)
>>>>
>>>> adam at boninlaw.com
>>>>
>>>> http://www.boninlaw.com
>>>>
>>>>
>>>>
>>>> From: law-election-bounces at department-lists.uci.edu [mailto:
law-election-bounces at department-lists.uci.edu] On Behalf Of Smith, Brad
>>>> Sent: Saturday, August 03, 2013 2:19 PM
>>>> To: law-election at UCI.edu
>>>> Subject: Re: [EL] “Citizens United poised to destroy judicial
impartiality”
>>>>
>>>>
>>>>
>>>> What I always find odd when I read such commentary as that of Justice
Nelson (1st item below) is the sense that this is somehow new. Is Justice
Nelson unaware that prior to 2010 a majority of states, many of which have
an elected judiciary, allowed unlimited corporate expenditures? That even
in other states and federally, corporations could fund "issue ads," in some
states right up until the election, in a few only more than some days out?
>>>>
>>>>
>>>>
>>>> I can understand arguments against Citizens United, and why people
disagree with the decision, but I am constantly baffled by what seems to be
the sheer unwillingness to consider the probable consequences of Citizens
United in light of the law prior to 2010.
>>>>
>>>>
>>>>
>>>> Bradley A. Smith
>>>>
>>>> Josiah H. Blackmore II/Shirley M. Nault
>>>>
>>>>    Professor of Law
>>>>
>>>> Capital University Law School
>>>>
>>>> 303 E. Broad St.
>>>>
>>>> Columbus, OH 43215
>>>>
>>>> 614.236.6317
>>>>
>>>> http://law.capital.edu/faculty/bios/bsmith.aspx
>>>>
>>>> ________________________________
>>>>
>>>> From: law-election-bounces at department-lists.uci.edu [
law-election-bounces at department-lists.uci.edu] on behalf of Rick Hasen [
rhasen at law.uci.edu]
>>>> Sent: Saturday, August 03, 2013 1:56 PM
>>>> To: law-election at UCI.edu
>>>> Subject: [EL] ELB News and Commentary 8/3/13
>>>>
>>>> “Citizens United poised to destroy judicial impartiality”
>>>>
>>>> Posted on August 3, 2013 10:50 am by Rick Hasen
>>>>
>>>> Former Montana Supreme Court Justice James C. Nelson, Supreme  who
dissented (and was ultimately vindicated) by the United States Supreme
Court in ATP v. Bullock, has written this oped for the Missoulian.
>>>>
>>>> [A}ccording to the Supreme Court, while contributions directly to a
candidate breed corruption, corporate expenditures on behalf of a candidate
do not have any such corruptive effect.
>>>>
>>>> For those living in a parallel universe that nuance may make sense,
but, in reality it is a dichotomy grounded in utter fiction. Worse, this
canard presents a clear and present danger for the majority of states, like
Montana, where voters elect their judges and justices. Citizens United
applies to judicial elections, too. Make no mistake; its effects will
dominate judicial elections.
>>>>
>>>> <image001.png>
>>>>
>>>> Posted in campaign finance, judicial elections | Comments Off
>>>>
>>>> “D.C. group not happy with how Indiana handling complaint”
>>>>
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>>>
>>> --
>>> Steve Klein
>>> Staff Attorney & Research Counsel*
>>> Wyoming Liberty Group
>>> www.wyliberty.org
>>>
>>> *Licensed to practice law in Illinois. Counsel to the Wyoming Liberty
Group pursuant to Rule 5.5(d) of the Wyoming Rules of Professional Conduct.
>>
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