iPhone app iPad app Android phone app Android tablet app More

Featuring fresh takes and real-time analysis from HuffPost's signature lineup of contributors
Doug Kendall

GET UPDATES FROM Doug Kendall
 

Reversing Citizens United

Posted: 01/21/12 11:07 AM ET

Do we need a constitutional amendment to overturn the Supreme Court's ruling in Citizens United v. FEC? Should opponents of the ruling pressure the Supreme Court to reverse course, and also seek changes in the composition of the Court through the appointment process? The answer is yes. That is the lesson one gleans from a careful study of the successful effort by progressives at the turn of the 20th Century to overturn the Supreme Court's 5-4 ruling in Pollock v. Farmers' Loan & Trust Co., through ratification of the Sixteenth Amendment.

The parallels between the Court's rulings in Pollock and Citizens United are striking. In 1895, a sharply-divided Supreme Court, led by a five-Justice, conservative, pro-corporate majority, overturned long-standing Court precedents to strike down a federal income tax statute, effectively eliminating the federal government's ability to enact and enforce a progressive tax on incomes. The dissenters in Pollock castigated the ruling for departing from settled constitutional principles, with Justice John Marshall Harlan called the ruling a "disaster" "subjugating the people to 'the dominion of aggregated wealth." The Pollock ruling ushered in a 40-year period, derisively known today as the Lochner-era, during which a conservative Supreme Court issued dozens of rulings that established a constitutional barrier to the regulation and taxation of corporations. Pollock inflamed the nation, leading to calls to pass a new income tax statute to force the Court to reverse itself as well as to calls to adopt a constitutional amendment.

Citizens United, like Pollock, was a 5-4 ruling by a conservative majority on the Supreme Court. Like Pollock, Citizens United reversed prior Court precedent and departed from constitutional first principles: corporations are not citizens, and they cannot vote or run for office, but the Citizens United majority nevertheless ruled that corporations can overwhelm the political process with money generated by special privileges they alone receive. Citizens United also drew a lengthy and powerful dissent, authored by Justice John Paul Stevens, that affirmed the government's broad power to regulate corporations in the interest of "We the People." Like Pollock, Citizens United was not an isolated ruling or an outlier: it is one of many rulings by the Roberts Court that favor corporate interests. And, as polling and President Obama's harsh condemnation of the Court's ruling indicate, it too has generated strong and widespread opposition.

The story of how the American people worked to overturn Pollock is thus directly relevant to advocates working to overturn Citizens United today. In a relatively short span of time in the midst of the Lochner-era, the campaign to overrule Pollock succeeded with the ratification of the Sixteenth Amendment, expressly affirming that Congress has broad power to enact a progressive income tax and bringing the Constitution back in line with first principles that give Congress broad power to solve national problems. This is an inspiring reminder that the American people can mobilize successfully to take the Constitution back from the Court. Those who think an amendment overturning Citizens United is a pipedream need to wrestle with this history and the fact that the Pollock/Sixteenth Amendment story is not an isolated one. Throughout our history, the American people have amended the Constitution in order to undo Court rulings that misinterpreted the Constitution. In addition to the Sixteenth Amendment, the Eleventh, Fourteenth, and Twenty-Sixth amendments were all sparked, at least in part, by divided Supreme Court rulings. In these Amendments, the American people agreed that the dissenting opinions, not the majority, better articulated the meaning of the Constitution.

The story of Pollock and the Sixteenth Amendment also demonstrates that, in a campaign to overturn a Supreme Court decision, an amendment strategy and an effort to push the Court to reconsider its ruling can go hand-in-hand. As pressure on the Court to reverse course mounted, some conservatives got behind an amendment to save the Court from having to admit error. Other conservatives cynically supported an amendment believing that - because the amendment process is extremely difficult - this was the best way to head off any responsive action. This strategy backfired when Congress and 42 states voted to ratify the Sixteenth Amendment, fully enshrining the progressive income tax in our nation's charter. This shows that the political winds blow in strange ways and it is never wise to put all one's eggs in any particular basket.

Finally, the post-ratification history of the Sixteenth Amendment indicates that the opponents of Citizens United should not be satisfied even if the ruling is ultimately reversed by the Court or effectively overturned by an amendment. Because the progressive opponents of Pollock did not decisively alter the composition of the Lochner-era Court, the era continued on for more than two decades after ratification of the Sixteenth Amendment. Indeed, the Lochner-era Court gave a stingy reading to the Sixteenth Amendment itself, reading it to preserve a significant part of Pollock's reasoning. It was only after President Franklin Roosevelt dramatically changed the composition of the Supreme Court that the Lochner-era, and the vestiges of Pollock, disappeared from the law.

This Progressive Era history yields three critical lessons for modern progressives fighting Citizens United. First, fights to overturn Supreme Court rulings are long hauls, which often play out over decades, not years. Second, amendment campaigns and political efforts to pressure the Court itself to reverse course can complement each other, sometimes in surprising ways. Third, to truly be successful, any effort to overturn a particular decision must be supplemented with a broader effort to change the composition of the Court through appointments.

Reversing Citizens United will not be easy, as anyone who has been working in opposition to the ruling for the two years since it was decided already knows. But the progressive reformers of a century ago have shown us how it can be done.

(This post was written with David Gans and Ryan Woo, the lead authors of Constitutional Accountability Center's new Issue Brief, Reversing Citizens United: Lessons from the Sixteenth Amendment.)

 

Follow Doug Kendall on Twitter: www.twitter.com/myconstitution

 
 
  • Comments
  • 576
  • Pending Comments
  • 0
  • View FAQ
Comments are closed for this entry
View All
Favorites
Highlights
Bloggers
Recency  | 
Popularity
Page: 1 2 3 4 5  Next ›  Last »  (9 total)
Genders
Love, Tolerance, Enlightenment
10:14 PM on 01/22/2012
Sign Kucinich's petition to outlaw campaign contributions as the bribes they are, and publicly finance all elections.

http://kucinich.us/

send him 10 bucks if you can.

Kucinich is a great American hero.
photo
HUFFPOST SUPER USER
unitarianuniversalist
A Bernie Sanders Proud Socialist Liberal
06:25 PM on 01/22/2012
Though I can only guess that the damage done by the Supreme Court decision to make corporations human beings will not be reversed in my lifetime, I am willing to fight the good fight that future generations may benefit from an amendment to overturn the interests of the wealthy. Let's FIGHT!
HUFFPOST COMMUNITY MODERATOR
1088
10:12 AM on 01/22/2012
You heard the man Justice Scalia, if you don't like it, switch the channel. You see, that is what you get when you vote in a Republican President, that will stack the courts with these corrupt creatures.
photo
HUFFPOST SUPER USER
AmosKnows
Educating The American Idol Masses
11:28 AM on 01/22/2012
See what you get when you vote for a democratic president:

“I suspect the real purpose of this bill (NDAA) is to thwart internal, domestic movements that threaten the corporate state,” says Hedges. “The definition of a terrorist is already so amorphous under the Patriot Act that there are probably a few million Americans who qualify to be investigated if not locked up.” When that piece of legislation is coupled with NDAA, the end result could be catastrophic."

Obama administration puts detention of American citizens back in NDAA after it was taken out:

http://www.youtube.com/watch?v=8VSbGRhQWG4&feature=player_embedded#!

Obama administration says killing US citizens abroad okay without due process:

http://www.washingtontimes.com/news/2011/oct/11/obamas-killing-of-us-citizens/
photo
modeforjoe
We had the experience, but we missed the meaning
08:16 PM on 01/22/2012
Brilliant post. What Obama has done and is doing is more dastardly than what the Supreme Court has done.

The Citizens United thing is a menace; but if our public schools can turn out a generation of thoughtful citizens (which they do only for a few at present) then the money spent on ads will be laughed off by an informed electorate.

But the Obama decision; that is a dagger in the heart. A real dagger.
09:12 PM on 01/22/2012
It was already law to indefinitely detain United States citizens without trial. Both the Bush and Obama administrations claimed the 2001 Authorization for military force allowed them to do so and courts backed them up on their claims. The NDAA was basically irrelevant where indefinite detention of citizens is concerned.
09:25 AM on 01/22/2012
16th Amendment was ratified in 1913, I think.

That Amendment overturned a bad decision by the USSCs(Pollock vs Farmers Loan and Trust).

And I am sure all the agitation from the American people over Pollock probably had the Court at the time as defensive as the Court today is with its horrendous "Citizens United" case.

This was an informative article that does give us hope.

It is not impossible to undo the damage wrought by the majority of the Court on "Citizens United".

It may not even take as long as it took to ratify the 16th Amendment.
photo
HUFFPOST SUPER USER
Paul Davenport
I'll show you my micro-bio if you'll show me yours
04:54 AM on 01/22/2012
Enlightning, relevant, inspiring and so damn critically important as Americans fight back against the Plutocracy's efforts to overwhelm the entire planet. This singular issue needs to be brought forward as the defining battle cry for all of America, its childrens' future and mankind as a whole.
Where can I "sign up"? (seriously)
photo
HUFFPOST SUPER USER
unitarianuniversalist
A Bernie Sanders Proud Socialist Liberal
06:28 PM on 01/22/2012
Paul, I'm with you on this. This is a fight for the future of our children and their children after them. We must begin TODAY to insure a better tomorrow.
guajiro
posted 5 minutes ago
01:03 AM on 01/22/2012
Seriously, thank you Doug. That aspect of history I had never read about and it truly lifts the somber perception of the legal system of this country that I had developed. As in SOPA, writing our representatives and funding those with whom we agree will have an impact, not now, but in soon enough time. Meanwhile, back to the trenches for me. Thanks and out Doug.......
10:37 PM on 01/21/2012
That corporations have First Amendment rights was settled law, not something that was new to Citizens United. If you don't believe me, read the concurrence. See page 41 of Justice Stevens concurrance-dissent

"We have long since held that corporations are covered by the First Amendment"
photo
HUFFPOST SUPER USER
aacme
My micro-bio is on a strict need-to-know basis.
08:15 PM on 01/22/2012
Everybody is covered by all amendments,
It is the definition of first amendment rights as including unlimited, undisclosed political donations of hard cash that is at issue here.
09:14 PM on 01/22/2012
That corporations are covered by the first amendment isn't the issue. The issue is unlimited spending during elections that either corrupt the process or create the appearance of corruption.
HUFFPOST SUPER USER
worker beenumbed
08:43 PM on 01/21/2012
I would like to see a fee called The Occupation of the Airwaves bt the Superpacs Fee.Charge 50 cents for every dollar transferred to a broadcaster from a superpac.A limited supply of airwaves did not exist during 1700s
02:49 AM on 01/22/2012
I have been against publically funded elections, mainly because of the idea that my money went to causes that I do not support but your post has tempered my opinion. We could fund national elections from a 100% tax on all political ads to be devided among recognized candidates. Lets see how much these unchecked, irresponsible sources are willing to spend on their causes knowing their money is going to help fund a more balanced elections. They can truely test the strength of their message against equally funded candidates. Like revenue sharing in professional sports ... there is another idea, campain "salery caps" if a campain spends more than the allowed limits they have to pay a "fine" that gets divided among the other candidates. This is fun ...
photo
HUFFPOST SUPER USER
aacme
My micro-bio is on a strict need-to-know basis.
08:22 PM on 01/22/2012
Except that if elections were publically funded, the ads would have been paid for by the same tax that they would generate.
No outside ads should be allowed. Each qualified candidate should get the same amount of tax money and be audited to see if that total was exceeded, on pain of disqualification. Period. No more halfway BS calculated to allow the superrich and corporations to control everything. The situation we have now is a back-handed coup d'etat.
photo
HUFFPOST SUPER USER
aacme
My micro-bio is on a strict need-to-know basis.
08:26 PM on 01/22/2012
And if elections were publicly funded the Congress could actually spend its time on the people's business, not on raising campaign cash and, beyond that, feathering their nests.
My new bumper sticker:
Give a Politician Money-Go to Jail.
photo
rodjard
I Update my brain frequently
07:01 PM on 01/21/2012
The nation is finally on track to liberate itself from these
insufferable corporate fascists. Democracy of the people
will finally right itself for smooth sailing for many years to
come. Much progress has already been made in spite of
them.
The Courts, The Congress The Presidency and the Free Press
all are rejecting the old Dogma of the right.
nadinehack
Exec-in-Residence IMD & CEO beCause Global
01:09 PM on 01/21/2012
I am so glad that Stephen Colbert has been mercilessly bringing attention to the absurdity of this decision allowing unlimited corporate spending on political campaigns. I did a piece about this on Levick BulletProof blog on Mar 1 2010 http://bit.ly/wpVaUU. I'm happy there is spirited public debate on this once again. - Nadine B. Hack
photo
HUFFPOST SUPER USER
DrJykell
Truth hunter
12:22 PM on 01/21/2012
Americans are just going to have to study harder---and become more informed----and they can spend all the money they want-----if you understand it takes decades of policy to realize economic results in real time----the short term arguments all fall by the wayside----

You begin to realize how empty the political rhetoric truly is around election time!
American corporations give up on democracy decades ago and have been fighting it constantly..

Promises---promises---false narratives---false understandings----fear and spin--fear and spin
photo
T Trump
Sarcasm / Truth / Mocking
12:01 PM on 01/21/2012
Citizens United needs the death penalty with no appeals allowed. I will be glad to pull the switch.
rogergoldkin
If you think education is expensive, try ignorance
07:22 AM on 01/22/2012
I'll be right behind you cheering you on!
photo
HUFFPOST SUPER USER
aacme
My micro-bio is on a strict need-to-know basis.
08:31 PM on 01/22/2012
Corporate citizenship is limited. Only positive aspects. No responsibilities or liabilities.
All the rest of us are second-class citizens, the only ones the death penalty applies to.
photo
Kristin Talbott
One should always be a little improbable.
11:58 AM on 01/21/2012
Reversing Citizens United isn't going to solve the problem. The problem is allowing artificial entities constructed on paper to have the same rights as actual human beings. That decision, Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886), is well over a century old and, thus, we have over a century of history to look at to see just how damaging it has been.

I won't even attempt to detail the numerous ways in which that decision (which was really just a refusal to hear arguments on the issue) was an affront to logic and common sense. The larger point is that it created a class of "citizens" who have all of the rights of citizens, but none of the mechanisms (empathy, guilt, a sense of responsibility, a desire to do the right thing) that allow humans to exercise their rights (by and large) responsibly. In other words, it created a class of citizens that would always and forever consist entirely of sociopaths and, because there are virtually no limits on how wealthy and powerful they are allowed to become, these artificial entities now run our entire society.

Reversing Citizens United would be all fine and good, but we shouldn't make the mistake of thinking that doing so would solve the real problem.
photo
HUFFPOST SUPER USER
DrJykell
Truth hunter
12:09 PM on 01/21/2012
By the time they do---it probably would mean they've already figured out away around whatever reforms are implemented... After all the pacs would probably be the writers of the amendment!
T-Haight
What was wrong with federalism?
11:33 AM on 01/21/2012
When was the last time that a constitutional amendment passed restricting free speech? That would be never. And if it's okay to limit speech for corporations, what other non-people can be prohibited from speaking their minds? Churches? Universities? Newspapers (also for-profit corporations)? The question of how you could ever hope to differentiate between a for-profit corporation and a legitimate news outlet alone make corporate speech restrictions a Herculean task.

Critics of Citizens United would be better served to focus on disclosure laws, preferable in a non-partisan way this time (unlike the efforts prior to the 2010 election).
photo
HUFFPOST SUPER USER
Paperless Tiger
11:54 AM on 01/21/2012
Oh please. Citizens United is a deliberate misinterpretation of the law to encourage corporate plutocracy, we all know that. If you don't know the difference between a newspaper and a corporatist attack ad, God help you.
T-Haight
What was wrong with federalism?
05:31 PM on 01/23/2012
So in other words, all you have to do to be allowed to express your opinion is buy a newspaper or start your own news station? Brilliant! I'm sure that nobody in a million years will think of such a tactic!
photo
suzc
Speak the Truth, even if your voice shakes
01:38 PM on 01/21/2012
Oh, please. Don't be stupid. And don't assume all of us are stupid.
Repeat after me:
Money is Not Speech.
Corporations are Not People.
And a plastic Jesus in a bottle of urine isn't Art.
Period.
These (and others) are "legal myths" created to keep the powerful in power and everyone else subservient -- and it's working pretty well.
PS Freedom of the Press is a separate freedom.
photo
HUFFPOST SUPER USER
aacme
My micro-bio is on a strict need-to-know basis.
08:37 PM on 01/22/2012
As is freedom of religion.

When a class of super citizens, with rights but not responsibilities, is created, everyone else is a 2nd class citizen.
There are corporations I would propose for the death penalty, but they are exempt.
T-Haight
What was wrong with federalism?
05:32 PM on 01/23/2012
Um, none of the things you wrote are actually connected to what I wrote. Sorry.
HUFFPOST SUPER USER
Mark MacDonald
Pass the Scotch
11:15 AM on 01/21/2012
Thank you in a good lesson in history. Progressives who are planning to sit out the next election should consider that the next Supreme Court Justice to retire will more than likely be Ginsburg. Should President Obama not win the election her replacement will be someone favorable to the Citizens United ruling.