Introduction 

In 2024, external election spending in the United States soared to a record high of nearly 4.5 billion dollars (Massoglia). Over 50% of this spending originates from groups who at least partially obfuscate their donors. This largely unaccounted-for portion of expenditures is known as “dark money”––a relatively recent term referring to undisclosed campaign funds (Briffault). While outside campaign financing is not a novel phenomenon by any means, the influx of dark money in elections primarily developed in the wake of the landmark 2010 Supreme Court decision Citizens United v. FEC, which fundamentally altered campaign financing, codifying the expanded protection of corporate political donations under the First Amendment (Gerken). However, though the impact of Citizens United is polarizing and widely contested, the significance of the ruling itself is only an extension of previous cases that had already diminished the efficacy of campaign spending regulation (Kang 4). Namely, in FEC v. Wisconsin Right to Life, Inc., where the Supreme Court severely curtailed the ability of the government to regulate corporate spending on advertisements (United States, Supreme Court). Though partially inadvertent, relaxed spending regulations stemming from Citizens United and other similar cases have allowed dark money to flow into elections at an increasing rate (Evers-Hillstrom). 

The sweeping effects of cases like Citizens United pose an existential threat to the foundational principles of democracy in the United States. Decision-making power in the United States elections no longer belongs to the citizens; instead, it lies in the hands of the wealthy and corporations. Put simply, the United States has become, for all intents and purposes, organized as an oligarchical state. Without comprehensive reform, the integrity of elections and the political system as a whole will continue to be undermined at every turn. In order to diminish the pernicious reach of third-party campaign financing, a multifaceted solution involving both strengthened regulations and additional public funding options is the best route to substantial reform. 

Contextualizing Campaign Financing

Contemporary campaign financing is situated within––and influenced by––the broader evolution of campaign financing regulations. During the late 19th century and early 20th century, the United States was rife with political and governmental corruption (White 2–10). The rise of big business coupled with laissez-faire economic policies led to the proliferation of industrial monopolies, which, in turn, ushered in an era of pervasive campaign and electoral monetary manipulation. (Calhoun 239–60). Throughout this period, commonly referred to as the Gilded Age, Congress was effectively bought out by industry giants (Crichton et al.). However, political corruption spurred progressive era reforms. Beginning with the Tilman Act in 1907, which prohibited corporate donations to federal campaigns, legislation was enacted to mitigate corruption (Laider and Turek 13–14). Subsequent acts, notably the 1971 Federal Election Campaign Act (FECA) and the 2002 Bipartisan Campaign Reform Act (BCRA), attempted to limit undue private influence and create a robust framework for transparency (Jones). Debate persisted as to the efficacy of the latter two acts; nevertheless, there was a general, observable push throughout the 20th century to enact regulations regarding campaign financing (Adamany and Agree; Mann). 

Though monumental legal and political shifts have taken place since the height of Gilded Age corruption, the current economic landscape of the United States presents a structural parallel in terms of wealth inequality; income inequality has reached its highest level since the Gilded Age (Martin). While the question of whether the United States has entered an altered version of Gilded Age corruption is beyond the scope of this article, the implications of widespread wealth disparity must be considered when evaluating the ways in which the democratic system is threatened by campaign spending deregulation (Ross). In many ways, with the Citizens United ruling and earlier precedents, the United States is digressing into a state not dissimilar to Gilded Age political corruption.  

The Illegitimacy of Citizens United

A century of progressive reforms was functionally overruled in a single decision. In January of 2008, after the non-profit organization Citizens United published and attempted to promote a film disparaging then-Senator Hillary Clinton, the group’s efforts were blocked by the FEC (Fredrickson and Wurman). Seeking an injunction against the FEC, Citizens United argued that the court was unconstitutionally applying the BCRA and held that their movie was protected under free speech. Their efforts were eventually successful, and the court ruled 5-4 for Citizens United (Oyez). Though the technical aspects of the court’s logic were extensive, the general decision can be distilled as follows: corporations are fundamentally associations of people and are, thus, protected under the First Amendment to exercise extensive political speech (Purdue Global Law School). 

Citizens United is predicated on the notion that corporations ought to be treated as virtually indistinguishable from individual citizens or collectives; this theory of corporate personhood, which long predates Citizens United, is frequently contested in scholarship (Bowie; Jackson; Millon). Fundamentally, Citizens United requires the American public to recognize corporations as people, subject to the same laws and granted the same inalienable rights (Greenfield). This concept is psychologically incoherent and, more relevantly, incongruent with corporate law and history: across disciplines, corporations are established as “artificial, metaphysical, and legal construct[s] that exist separate and apart from its investors” (Brown; Macey and Strine 451). In addition, “normative citizenship,” wherein formal citizens engage in an obliged social contract with a nation-state, is incompatible with corporate political speech protections as corporations are distinct from actual citizens (Sepinwall). 

Aside from the invalidity of the ruling itself, the disastrous aftermath of Citizens United is reason enough to repudiate its acceptance. Citizens United is not remotely as consequential in isolation; instead, it serves as the latter portion of a sequence of decisions that hold the “potential for corporate speech to overwhelm the democratic system built to serve individual voters” (Levitt 223). The primary route through which Citizens United sanctioned increased corporate influence is the insidious rise of “super-PACs”––entities that engage in solely independent expenditures and may, in turn, raise money without limits (Kang 34). Accordingly, donors to super-PACs avoid all corruption risks, only furthering the extent of fundraising. Super-PACs are, in all forms, conducive to crushing the political leverage of average voters, thereby inherently unbalancing the political system; they allow the wealthiest few to retain an outsized influence on elections, tipping the decision-making power towards the most affluent (Smith and Ghosh). In other words, the United States has transformed into a largely oligarchical state, an idea supported by empirical research (Gilens and Page). 

Bolstering the impression that Citizens United is antithetical to democracy, examinations of democracy indexes post-Citizens United yield evidence to suggest that dark money emerging after the ruling diminishes state-level indicators of democraticness (Teirstein). As anticipated, similar research finds that dark money lobbying prevents proactive climate change legislation as firms are able to effectively pay their way out of regulation (Rocchi). These malicious lobbying practices, enhanced by super-PACs, are incompatible with functioning democratic and bureaucratic systems. 

Democracy and Dark Money

To understand the implications of the ubiquitous effects of Citizens United, a deceivingly simple question may be posed: What constitutes bribery? Over the past decade, the Supreme Court has systematically narrowed the definition of political bribery, threatening the integrity of democracy. Under Section 201 of Title 18 of the United States legal code following the Foreign Corrupt Practices Act, bribery is strictly forbidden (Legal Information Institute). Disallowing bribery is non-negotiable in a democratic system; bribery and political dishonesty erode democratic functioning, thereby decreasing political efficacy (Rivera et al.). 

However, the Supreme Court has varied its approach to addressing bribery based on whether foreign or domestic officials are involved, leading to a double standard that is increasingly permissive of domestic bribery (Mance and Mistree). Citizens United created an economic and political environment where officials can circumvent being accused or convicted of receiving bribes due to unlimited spending caps and dark money. Practically, Citizen United only outlaws explicit quid pro quo arrangements, which narrows the accepted scope of political corruption to the point of undermining all regulation (Raban). By all general accounts, Citizens United legalized bribery––bribery that is often entirely untraceable through dark money.

Dark money is particularly concerning as it is frequently utilized––to varying decrease of efficacy––in a manipulative, quasi-legal context in order to protect donor organizations and corporations from legal scrutiny (Irvin). More generally, dark money usage is associated with increased spending altogether (Schnakenberg and Turner). Socioculturally, meanwhile, dark money has extensive ties to radical movements, particularly within the far-right (Mayer). In every observable facet, the flood of dark money into American politics is a threat to democracy (Whitehouse, Does Democracy Die with Dark Money?). Therefore, the Supreme Court, in Citizens United, chose to preserve a bastardized version of corporate speech over the political equality of the nation. 

A Path Forward

Citizens United is broadly unfavorable among the American public; polling indicates a majority of both Democrats (85%) and Republicans (66%) would support a Constitutional Amendment overturning the ruling (Balcerzak). As such, multiple candidates have run on platforms promising the abolition of Citizens United (Marciniak). Scholarly critiques point out, however, that the presence of earlier established precedents would render this effort largely void (Cole). Yet less acute methods have proved broadly ineffective: the vast majority of spending bans introduced post-Citizens United have had minimal effect on the partisan composition of voters, the success of particular parties, and re-election rates (La Raja and Schaffner). However, local restrictions have shown promise for bettering political equity; on a state level, greater campaign spending restrictions are associated with higher public welfare spending and lessened reliance on business contributions, promoting political equality and disadvantaged citizens' interests (Flavin). 

Thus, systemic reform may be possible through sustained, localized changes. In lieu of another theoretical proposal, the effectiveness of state-level efforts is illustrated by New York City’s Public Campaign Finance Program, which fights megadonors’ influence by matching small donations with public funds (Zdanys). While some older literature does point to the variability of these programs’ effects, suggesting they may not be wholly transformative, evidence from the New York City Campaign Finance Board indicates that the program shows promise at increasing candidate accountability and voter participation while decreasing extraneous special-interest influence (Klumpp et al.; New York City Campaign Finance Board). If implemented more extensively, the program and similar strategies have the potential to curb insidious campaign spending by corporate entities and the extremely wealthy. Additional preliminary research does posit the potential benefits of both partial (so-called “matching programs”) and full public funding in United States elections; publicly funding elections does seem to incentivize competitive elections and reduce private influence, but it does so at the expense of heightened ideological polarization and extremism (Fouirnaies). Still, public funding of elections is also widely disliked by voters; despite their upset at the existing system, most refuse to incur additional taxes to reduce special-interest financing in elections (La Raja and Schaffner, “Explaining the Unpopularity of Public Funding for Congressional Elections”). Furthermore, empirical evidence remains limited due to the dearth of actual iterations of matching programs, which remain broadly corrective rather than fully ameliorative. 

Additionally, public funding solutions lack measures addressing disclosure requirements to eliminate dark money. A varied, systematic approach must be taken to combat dark money: first, the courts must undergo a comprehensive regulatory overhaul with mandates for disclosure of major donors and funding from any organization that files three or more amicus curiae briefs upon nomination; second, more stringent guidelines must be enforced on all organizations, such as limiting political engagement, requiring public release of IRS Form 990 contributions, and redesigning funding data collection systems for easier public access and accountability; third, Treasury and IRS amendments must be codified, tightening 501(c)(4) regulations to ensure these registered organizations act for the benefit of general welfare instead of political motives (Kirby; Shaw et al. 153–171; Whitehouse). This multifaceted approach provides a broad-encompassing solution to the systemic influx of dark money. 

Returning to the proposal of a Constitutional Amendment overturning Citizens United––is this idea both worthwhile and possible in spite of criticism? Putting feasibility aside, a few critics argue an amendment would grant Congress an excess of power, spurring political corruption (Samples). However, these analyses neglect to recognize the true capacity Citizens United has for damage, minimizing its effects on political corruption. The viability of a constitutional amendment is minimal; successful passage would require ratification by three-fourths of state legislatures––an unlikely reality given the contentiousness of Citizens United and pervasive partisan gridlock, which renders collective action on societal problems nearly impossible (Ichel and Siegel 447–482). In fact, this amendment has been attempted before and failed: in 2014, a proposed amendment overturning Citizens United was rejected (54-42) by the Senate (United States Senate). Though less definitive and effectual, positive change could arise from merely addressing the loopholes and primary issues borne out of Citizens United—as explored in later cases such as United States vs. Householder (2023)––rather than rejecting the entire ruling (Shih). One such remedial solution proposes joint contracts between opposing parties that constitute an arrangement to reduce external funding (Sitaraman).

Conclusion 

The current political and electoral landscape is undoubtedly bleak. Corporate spending continues to grow, and billion(s) of dollars of untraceable dark money flow steadily into campaigns––a resurgence generated after waves of regressive, often egregiously flawed court rulings, foremost among them Citizens United. In a manner reflecting earlier political corruption, the inundation of corporate financing in elections has distinct, overwhelmingly negative implications for the integrity of American democracy, ideological polarization, and the nation's stability as a whole. Combating corporate election spending is a complex battle that requires well-rounded solutions encompassing multiple levels of government and establishing extensive laws and regulations. Reform remains tenuous but possible. However, it is worth remembering that the American public is not all that divided on this issue: they want decisive, sweeping shifts in the structure and execution of election funding; they want change.

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