Subject: Re: [EL] FW: Floyd Abrams & Citzens United
From: "Scarberry, Mark" <Mark.Scarberry@pepperdine.edu>
Date: 10/3/2010, 9:00 AM
To: "election-law@mailman.lls.edu" <election-law@mailman.lls.edu>

Re: [EL] FW: Floyd Abrams & Citzens United
And what about corporations like the Sierra Club (incorporated in 1892, http://www.sierraclub.org/history/olney.aspx), the ACLU (a 501(c)(4) corporation, and the ACLU Foundation, its 501(c)(3) charitable affiliate, http://www.aclu.org/american-civil-liberties-union-and-aclu-foundation-what-difference and http://www.aclupa.org/home/abouttheaclu/acluvsaclufoundation.htm), the American Constitution Society (https://secure.acslaw.org/joinnow/donation.php?type=Join), and the Federalist Society (https://www.fed-soc.org/for_donors/donate.asp)? All of them have limited liability, yet none of us would argue that they lack free speech rights.
 
Whether 501(c)(3) corporations like churches, the ACLU Foundation, the ACS, and the FS ought to be able to support or oppose candidates for office and ought to be able to engage in substantial lobbying without losing their tax exempt status is a separate question. I've pointed out that one religious leader (John Leland) supported Madison in two critical elections, perhaps providing him the margin of victory. See John Leland and James Madison: Religious Influence on the Ratification of the Constitution and on the Proposal of the Bill of Rights, in 113 Penn State Law Review, http://ssrn.com/abstract=1262520. Of course, that was before there was a US income tax or a common practice of incorporating religious bodies.
 
Mark Scarberry
Pepperdine


From: election-law-bounces@mailman.lls.edu on behalf of Volokh, Eugene
Sent: Sun 10/3/2010 7:06 AM
To: election-law@mailman.lls.edu
Subject: Re: [EL] FW: Floyd Abrams & Citzens United


        (1)  That's a plausible argument for suspending limited liability in libel lawsuits against newspapers -- someone we don't do, and something that to my knowledge has not even been seriously suggested.  But it's not a plausible argument for restricting speech about candidates or ballot measures by corporations, where the worry is *not* that the corporation won't be able to pay any damages for libel and the like.  I quite doubt that when people worry about, say, Exxon spending money on election-related speech, the concern is that it won't be able to pay damages if the speech is libelous; I suspect Exxon has enough in its treasury, or enough coverage in its insurance policies, to take care of that.  In fact, the rich businesses that people most worry about in campaign finance debates are actually *more* likely to be able to be held "responsible for their abuses such as defamation" than the typical individual, who is more likely to lack sufficient assets or insurance to pay dam!
 ages.

        (2)  This also helps show how many of the creative arguments for restricting corporate speech apply as strongly (or even more strongly) to newspapers and other media that are organized as corporations.  Again, if one is really serious about protecting libel plaintiffs (as opposed to just using them as an excuse for restricting nonlibelous speech by corporations), one would be much more worried about libel in everyday stories by insufficiently capitalized media corporations than about libel in political ads run by insufficiently capitalized business corporations.

        Eugene

Paul Lehto writes:

> State constitutions from all time periods in our country's history
> provide for free speech, but  then commonly add that each person is
> "being responsible for the abuse of the right."
>
> While individuals in partnerships and associations remain responsible
> for their abuses such as defamation  (because each partner or member
> being liable individually)  this nexus of rights and liability called
> for in many state constitutions does not fit the corporation with its
> veil of limited liability because the shareholders are not responsible
> for the abuse of the right, if any.
>
> In the corporate context, they're trying to have rights without
> fulfilling the attendant duties that everyone else has.   Thus, it's
> not just that corporations are "persons" for First Amendment political
> purposes --  it's that they are a superior class of legal "person"
> specifically with respect to speech.

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