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16 J. App. Prac. & Process 305 (2015)
An Opening for Quid Pro Quo Corruption: Issue Advertising in Wisconsin Judicial Races before and after Citizens United

handle is hein.journals/jappp16 and id is 319 raw text is: AN OPENING FOR QUID PRO QUO CORRUPTION? ISSUE ADVERTISING IN WISCONSIN JUDICIAL RACES BEFORE AND AFTER CITIZENS UNITED Christopher Terry* and Mitchell T. Bard** I. INTRODUCTION A. The Law In Citizens United v. FEC,' the Supreme Court curbed the ability of Congress to limit campaign finance, holding that federal law limiting independent political expenditures by corporations, unions, and other organizations violated their free- speech rights under the First Amendment. The decision marked a major turning point in campaign-finance law, striking down pieces of the Bipartisan Campaign Reform Act of 2002,2 and overturning two Supreme Court precedents.3 Citizens United immediately set off a debate about the underlying principle at stake-whether money is a corrupting force in politics.4 * Ph.D., Assistant Professor, School of Journalism and Mass Communication, University of Minnesota. ** Ph.D., J.D.,' Assistant Professor, Department of Mass Communication, Iona College. 1. 558 U.S. 310 (2010). 2. 2 U.S.C. §441(b) (now codified as 52 U.S.C. § 30118 (2015)) [hereinafter BCRA]. 3. McConnell v. FEC, 540 U.S. 93 (2003), overruled by Citizens United v. FEC, 558 U.S. 310 (2010); Austin v. Michigan Chamber of Commerce, 494 U.S. 652 (1990), overruled by Citizens United v. FEC, 558 U.S. 310 (2010). 4. President Obama predicted in his 2010 State of the Union Address that the ruling would open the floodgates for special interests-including foreign corporations-to spend without limit in our elections, and emphasized that American elections should not be bankrolled by America's most powerful interests ... or ... by foreign entities. Barack Obama, Pres., U.S.A., State of the Union Address (Jan. 27, 2010), available at http://www .whitehouse.gov/the-press-office/remarks-president-state.union-address; see also, e.g., Molly J. Walker Wilson, Too Much of a Good Thing: Campaign Speech after Citizens United, 31 CARDOZO L. REv. 2365 (2010). THE JOURNAL OF APPELLATE PRACTICE AND PROCESS Vol. 16, No. 2 (Fall 2015)

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