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Contribution Limits after Citizens United Iliev Political Parties Super PACs

Contribution Limits after Citizens United Iliyan R. Iliev


March 24, 2014

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Party Contributions and Expenditures

FECA did not allow for independent spending by parties Parties and candidates coordinate their activities Should coordinated expenditures be limited? Colorado I (1996)

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Party Contributions and Expenditures

FECA did not allow for independent spending by parties Parties and candidates coordinate their activities Should coordinated expenditures be limited? Colorado I (1996)

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Party Contributions and Expenditures

FECA did not allow for independent spending by parties Parties and candidates coordinate their activities Should coordinated expenditures be limited? Colorado I (1996)

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Party Contributions and Expenditures

FECA did not allow for independent spending by parties Parties and candidates coordinate their activities Should coordinated expenditures be limited? Colorado I (1996)

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

No majority opinion Unconstitutional prohibits independent expenditures No evidence for corruption Soft money party activities, get out the vote drives Soft money presents no danger Cannot be used to inuence a federal campaign except in

limited party-building activities

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

No majority opinion Unconstitutional prohibits independent expenditures No evidence for corruption Soft money party activities, get out the vote drives Soft money presents no danger Cannot be used to inuence a federal campaign except in

limited party-building activities

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

No majority opinion Unconstitutional prohibits independent expenditures No evidence for corruption Soft money party activities, get out the vote drives Soft money presents no danger Cannot be used to inuence a federal campaign except in

limited party-building activities

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

No majority opinion Unconstitutional prohibits independent expenditures No evidence for corruption Soft money party activities, get out the vote drives Soft money presents no danger Cannot be used to inuence a federal campaign except in

limited party-building activities

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

No majority opinion Unconstitutional prohibits independent expenditures No evidence for corruption Soft money party activities, get out the vote drives Soft money presents no danger Cannot be used to inuence a federal campaign except in

limited party-building activities

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

No majority opinion Unconstitutional prohibits independent expenditures No evidence for corruption Soft money party activities, get out the vote drives Soft money presents no danger Cannot be used to inuence a federal campaign except in

limited party-building activities

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

Lack of coordination between the candidate and the

source of the expenditure (the party)


Are party expenditures dierent from contributions? How separate are the candidates and their parties? Do you think that party-building activities can be used

to promote a specic candidate? Should we dierentiate regular campaigns and party-building activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

Lack of coordination between the candidate and the

source of the expenditure (the party)


Are party expenditures dierent from contributions? How separate are the candidates and their parties? Do you think that party-building activities can be used

to promote a specic candidate? Should we dierentiate regular campaigns and party-building activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

Lack of coordination between the candidate and the

source of the expenditure (the party)


Are party expenditures dierent from contributions? How separate are the candidates and their parties? Do you think that party-building activities can be used

to promote a specic candidate? Should we dierentiate regular campaigns and party-building activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I

Lack of coordination between the candidate and the

source of the expenditure (the party)


Are party expenditures dierent from contributions? How separate are the candidates and their parties? Do you think that party-building activities can be used

to promote a specic candidate? Should we dierentiate regular campaigns and party-building activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II (2001)

Following Shrink Missouri coordinated expenditures are

a functional contribution limit


Parties do not speak generally of electing candidates Contributions to parties come from contributors with

personal interests
Parties are instruments of contributors who do not support

the partys message or candidates across the board, but specic candidates and specic positions on an issue

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II (2001)

Following Shrink Missouri coordinated expenditures are

a functional contribution limit


Parties do not speak generally of electing candidates Contributions to parties come from contributors with

personal interests
Parties are instruments of contributors who do not support

the partys message or candidates across the board, but specic candidates and specic positions on an issue

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II (2001)

Following Shrink Missouri coordinated expenditures are

a functional contribution limit


Parties do not speak generally of electing candidates Contributions to parties come from contributors with

personal interests
Parties are instruments of contributors who do not support

the partys message or candidates across the board, but specic candidates and specic positions on an issue

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II (2001)

Following Shrink Missouri coordinated expenditures are

a functional contribution limit


Parties do not speak generally of electing candidates Contributions to parties come from contributors with

personal interests
Parties are instruments of contributors who do not support

the partys message or candidates across the board, but specic candidates and specic positions on an issue

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II

Parties act as agents for spending on behalf of interests

who seek to produce obligated oceholders


Parties are not dierent from self-interested political actors Thomas, Scalia, Kennedy dissented Buckley should be

overruled
Parties should not be treated as individuals and political

committees
Parties are not instruments of the donors

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II

Parties act as agents for spending on behalf of interests

who seek to produce obligated oceholders


Parties are not dierent from self-interested political actors Thomas, Scalia, Kennedy dissented Buckley should be

overruled
Parties should not be treated as individuals and political

committees
Parties are not instruments of the donors

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II

Parties act as agents for spending on behalf of interests

who seek to produce obligated oceholders


Parties are not dierent from self-interested political actors Thomas, Scalia, Kennedy dissented Buckley should be

overruled
Parties should not be treated as individuals and political

committees
Parties are not instruments of the donors

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II

Parties act as agents for spending on behalf of interests

who seek to produce obligated oceholders


Parties are not dierent from self-interested political actors Thomas, Scalia, Kennedy dissented Buckley should be

overruled
Parties should not be treated as individuals and political

committees
Parties are not instruments of the donors

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado II

Parties act as agents for spending on behalf of interests

who seek to produce obligated oceholders


Parties are not dierent from self-interested political actors Thomas, Scalia, Kennedy dissented Buckley should be

overruled
Parties should not be treated as individuals and political

committees
Parties are not instruments of the donors

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I & II

Allow parties to spend independently without limit Limits on the spending that is coordinated with the

candidates
Do parties and candidates coordinate their eorts? Are there a lot of uncoordinated activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I & II

Allow parties to spend independently without limit Limits on the spending that is coordinated with the

candidates
Do parties and candidates coordinate their eorts? Are there a lot of uncoordinated activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I & II

Allow parties to spend independently without limit Limits on the spending that is coordinated with the

candidates
Do parties and candidates coordinate their eorts? Are there a lot of uncoordinated activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Colorado I & II

Allow parties to spend independently without limit Limits on the spending that is coordinated with the

candidates
Do parties and candidates coordinate their eorts? Are there a lot of uncoordinated activities?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money
Hard money contributions made with funds that are

subject to disclosure, source and amount limitations


Donations for state and local elections are not hard money Parties can use soft money for get out the vote drives

and generic party advertising


Soft money for legislative advocacy media

advertisements ads allowed even if the ads mentioned the name of a federal candidate, so long as they did not expressly advocate the candidates election or defeat
Support the Democratic Party, our candidate is John

Smith permissible?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money
Hard money contributions made with funds that are

subject to disclosure, source and amount limitations


Donations for state and local elections are not hard money Parties can use soft money for get out the vote drives

and generic party advertising


Soft money for legislative advocacy media

advertisements ads allowed even if the ads mentioned the name of a federal candidate, so long as they did not expressly advocate the candidates election or defeat
Support the Democratic Party, our candidate is John

Smith permissible?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money
Hard money contributions made with funds that are

subject to disclosure, source and amount limitations


Donations for state and local elections are not hard money Parties can use soft money for get out the vote drives

and generic party advertising


Soft money for legislative advocacy media

advertisements ads allowed even if the ads mentioned the name of a federal candidate, so long as they did not expressly advocate the candidates election or defeat
Support the Democratic Party, our candidate is John

Smith permissible?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money
Hard money contributions made with funds that are

subject to disclosure, source and amount limitations


Donations for state and local elections are not hard money Parties can use soft money for get out the vote drives

and generic party advertising


Soft money for legislative advocacy media

advertisements ads allowed even if the ads mentioned the name of a federal candidate, so long as they did not expressly advocate the candidates election or defeat
Support the Democratic Party, our candidate is John

Smith permissible?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money
Hard money contributions made with funds that are

subject to disclosure, source and amount limitations


Donations for state and local elections are not hard money Parties can use soft money for get out the vote drives

and generic party advertising


Soft money for legislative advocacy media

advertisements ads allowed even if the ads mentioned the name of a federal candidate, so long as they did not expressly advocate the candidates election or defeat
Support the Democratic Party, our candidate is John

Smith permissible?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money was 5% of party spending in 1984 42% in 2000 In 1996, 5 soft-money donors gave $9million In 2008, $300million from 800 donors, minimum donation

$120, 000

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money was 5% of party spending in 1984 42% in 2000 In 1996, 5 soft-money donors gave $9million In 2008, $300million from 800 donors, minimum donation

$120, 000

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money was 5% of party spending in 1984 42% in 2000 In 1996, 5 soft-money donors gave $9million In 2008, $300million from 800 donors, minimum donation

$120, 000

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money was 5% of party spending in 1984 42% in 2000 In 1996, 5 soft-money donors gave $9million In 2008, $300million from 800 donors, minimum donation

$120, 000

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money donations usually seek access, not ideological

support
Candidates solicit soft money donations direct donors to

tax-exempt organizations
Cases of candidates that advise supporters who reached

the legal maximum to use other means and make additional contributions
Is that corruption? Is soliciting contributions pressuring

the donors?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money donations usually seek access, not ideological

support
Candidates solicit soft money donations direct donors to

tax-exempt organizations
Cases of candidates that advise supporters who reached

the legal maximum to use other means and make additional contributions
Is that corruption? Is soliciting contributions pressuring

the donors?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money donations usually seek access, not ideological

support
Candidates solicit soft money donations direct donors to

tax-exempt organizations
Cases of candidates that advise supporters who reached

the legal maximum to use other means and make additional contributions
Is that corruption? Is soliciting contributions pressuring

the donors?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Soft Money

Soft money donations usually seek access, not ideological

support
Candidates solicit soft money donations direct donors to

tax-exempt organizations
Cases of candidates that advise supporters who reached

the legal maximum to use other means and make additional contributions
Is that corruption? Is soliciting contributions pressuring

the donors?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Outside Groups
PACs, 527 and 501c organizations

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Before Citizens United corporations could not spend their

general treasury funds on election activities


PACs can spend unlimited sums supporting or opposing

candidates
Contributions to PACs used to be limited to $5,000 Section 527 organizations not limited not political

committees, no contributions to candidates, no express advocacy

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Before Citizens United corporations could not spend their

general treasury funds on election activities


PACs can spend unlimited sums supporting or opposing

candidates
Contributions to PACs used to be limited to $5,000 Section 527 organizations not limited not political

committees, no contributions to candidates, no express advocacy

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Before Citizens United corporations could not spend their

general treasury funds on election activities


PACs can spend unlimited sums supporting or opposing

candidates
Contributions to PACs used to be limited to $5,000 Section 527 organizations not limited not political

committees, no contributions to candidates, no express advocacy

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Before Citizens United corporations could not spend their

general treasury funds on election activities


PACs can spend unlimited sums supporting or opposing

candidates
Contributions to PACs used to be limited to $5,000 Section 527 organizations not limited not political

committees, no contributions to candidates, no express advocacy

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

527 and 501

527s spent $400million in 2004 Soros was the biggest donor to 527s $24million No limit for contributions to 527s FEC began regulating 527s Shift to 501c social welfare organizations and other

nonprots
501c donors identity is hidden PACs, 527s, 501c spent $1.22billion in 2008

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow.org v. FEC (2010)

District Court case Speechnow is unincorporated nonprot Governments cap on donations to political committees is

unconstitutional
Applies to groups that dont make direct contributions to

candidates and dont coordinate with candidates when running independent advertisements

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow.org v. FEC (2010)

District Court case Speechnow is unincorporated nonprot Governments cap on donations to political committees is

unconstitutional
Applies to groups that dont make direct contributions to

candidates and dont coordinate with candidates when running independent advertisements

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow.org v. FEC (2010)

District Court case Speechnow is unincorporated nonprot Governments cap on donations to political committees is

unconstitutional
Applies to groups that dont make direct contributions to

candidates and dont coordinate with candidates when running independent advertisements

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow.org v. FEC (2010)

District Court case Speechnow is unincorporated nonprot Governments cap on donations to political committees is

unconstitutional
Applies to groups that dont make direct contributions to

candidates and dont coordinate with candidates when running independent advertisements

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow

The government has no anti-corruption interest in limiting

independent expenditures Citizens United


The denition of corruption is important Buying access is corruption before Citizens United Ingratiation and access are not corruption Citizens

United
Citizens United independent expenditures do not

corrupt or give the appearance of corrutpion


Given the denition, no anti-corruption interest in limiting

contributions to independent expenditure groups

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow

The government has no anti-corruption interest in limiting

independent expenditures Citizens United


The denition of corruption is important Buying access is corruption before Citizens United Ingratiation and access are not corruption Citizens

United
Citizens United independent expenditures do not

corrupt or give the appearance of corrutpion


Given the denition, no anti-corruption interest in limiting

contributions to independent expenditure groups

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow

The government has no anti-corruption interest in limiting

independent expenditures Citizens United


The denition of corruption is important Buying access is corruption before Citizens United Ingratiation and access are not corruption Citizens

United
Citizens United independent expenditures do not

corrupt or give the appearance of corrutpion


Given the denition, no anti-corruption interest in limiting

contributions to independent expenditure groups

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow

The government has no anti-corruption interest in limiting

independent expenditures Citizens United


The denition of corruption is important Buying access is corruption before Citizens United Ingratiation and access are not corruption Citizens

United
Citizens United independent expenditures do not

corrupt or give the appearance of corrutpion


Given the denition, no anti-corruption interest in limiting

contributions to independent expenditure groups

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow

The government has no anti-corruption interest in limiting

independent expenditures Citizens United


The denition of corruption is important Buying access is corruption before Citizens United Ingratiation and access are not corruption Citizens

United
Citizens United independent expenditures do not

corrupt or give the appearance of corrutpion


Given the denition, no anti-corruption interest in limiting

contributions to independent expenditure groups

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Speechnow

The government has no anti-corruption interest in limiting

independent expenditures Citizens United


The denition of corruption is important Buying access is corruption before Citizens United Ingratiation and access are not corruption Citizens

United
Citizens United independent expenditures do not

corrupt or give the appearance of corrutpion


Given the denition, no anti-corruption interest in limiting

contributions to independent expenditure groups

Contribution Limits after Citizens United Iliev Political Parties Super PACs

After Speechnow and Citizens United

FEC corporations and labor unions can also contribute

unlimited sums
District Court decided that PACs that make direct

donations to candidates may accept unlimited donations


501c organizations groups that did not disclose their

donors
501c spending rose from 1% to 47% since 2006

Contribution Limits after Citizens United Iliev Political Parties Super PACs

After Speechnow and Citizens United

FEC corporations and labor unions can also contribute

unlimited sums
District Court decided that PACs that make direct

donations to candidates may accept unlimited donations


501c organizations groups that did not disclose their

donors
501c spending rose from 1% to 47% since 2006

Contribution Limits after Citizens United Iliev Political Parties Super PACs

After Speechnow and Citizens United

FEC corporations and labor unions can also contribute

unlimited sums
District Court decided that PACs that make direct

donations to candidates may accept unlimited donations


501c organizations groups that did not disclose their

donors
501c spending rose from 1% to 47% since 2006

Contribution Limits after Citizens United Iliev Political Parties Super PACs

After Speechnow and Citizens United

FEC corporations and labor unions can also contribute

unlimited sums
District Court decided that PACs that make direct

donations to candidates may accept unlimited donations


501c organizations groups that did not disclose their

donors
501c spending rose from 1% to 47% since 2006

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Super PACs

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Coordination

Members of Super PACs former campaign managers,

relatives of candidates, share consultants


How can we control coordination?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Coordination

Members of Super PACs former campaign managers,

relatives of candidates, share consultants


How can we control coordination?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Incumbents v. Challengers

Overwhelming percentage of contributions contributions to

incumbents
Disproportionate support for candidates based NOT on

ideology and voting record, but their relative position of power and ability to return favors
Part of the logic behind Citizens United was protection of

challengers?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Incumbents v. Challengers

Overwhelming percentage of contributions contributions to

incumbents
Disproportionate support for candidates based NOT on

ideology and voting record, but their relative position of power and ability to return favors
Part of the logic behind Citizens United was protection of

challengers?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Incumbents v. Challengers

Overwhelming percentage of contributions contributions to

incumbents
Disproportionate support for candidates based NOT on

ideology and voting record, but their relative position of power and ability to return favors
Part of the logic behind Citizens United was protection of

challengers?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Lobbyists

Lobbyists are employed to inuence public ocials Lobbyists are individuals that enjoy constitutional rights Should people who directly inuence decision makers face

limits?
Individuals face contribution limits, certain organizations

do not
What if every individual forms a 501c?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Lobbyists

Lobbyists are employed to inuence public ocials Lobbyists are individuals that enjoy constitutional rights Should people who directly inuence decision makers face

limits?
Individuals face contribution limits, certain organizations

do not
What if every individual forms a 501c?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Lobbyists

Lobbyists are employed to inuence public ocials Lobbyists are individuals that enjoy constitutional rights Should people who directly inuence decision makers face

limits?
Individuals face contribution limits, certain organizations

do not
What if every individual forms a 501c?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Lobbyists

Lobbyists are employed to inuence public ocials Lobbyists are individuals that enjoy constitutional rights Should people who directly inuence decision makers face

limits?
Individuals face contribution limits, certain organizations

do not
What if every individual forms a 501c?

Contribution Limits after Citizens United Iliev Political Parties Super PACs

Lobbyists

Lobbyists are employed to inuence public ocials Lobbyists are individuals that enjoy constitutional rights Should people who directly inuence decision makers face

limits?
Individuals face contribution limits, certain organizations

do not
What if every individual forms a 501c?