Difference between revisions of "Super PAC"

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{{Super PACs}}{{tnr}}A '''[[Super PAC]]''' is a political committee that has no legal limits on its spending or the donations it accepts. A super PAC is not allowed to contribute directly to a politician or political party, but can spend independently to campaign for or against political figures. Hence, super PACs are officially called '''independent expenditure-only committees.'''<ref name="nytexp">[http://www.nytimes.com/interactive/2012/01/31/us/politics/super-pac-donors.html ''New York Times'' "Who's Financing the '[[Super PAC]]s?" May 7, 2012]</ref> [[Super PAC]]s are not legally considered a kind of [[Political action committee|political action committee]] (PAC), which have separate rules governing their activities.<ref name="at">[http://www.theatlantic.com/politics/archive/12/02/the-new-york-times-disingenuous-campaign-against-citizens-united/253560/ ''The Atlantic'' "The New York Times' Disingenuous Campaign Against Citizens United," February 24, 2012]</ref>
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{{Super PACs}}{{tnr}}A '''[[Super PAC]]''' is a political committee that has no legal limits on its spending or the donations it accepts. A Super PAC is not allowed to contribute directly to a politician or political party, but can spend independently to campaign for or against political figures. Hence, Super PACs are officially called '''independent expenditure-only committees.'''<ref name="nytexp">[http://www.nytimes.com/interactive/2012/01/31/us/politics/super-pac-donors.html ''New York Times'' "Who's Financing the '[[Super PAC]]s?" May 7, 2012]</ref> [[Super PAC]]s are not legally considered a kind of [[Political action committee|political action committee]] (PAC), which have separate rules governing their activities.<ref name="at">[http://www.theatlantic.com/politics/archive/12/02/the-new-york-times-disingenuous-campaign-against-citizens-united/253560/ ''The Atlantic'' "The New York Times' Disingenuous Campaign Against Citizens United," February 24, 2012]</ref>
  
 
In 1976 the [[judgepedia:Supreme Court of the United States|U.S. Supreme Court]] held that individuals have the right to spend as much as they want on independent political messaging. Wealthy individuals could, and did, spend extensively on elections.<ref name="will"/> With two 2010 rulings, the [[judgepedia:Supreme Court of the United States|U.S. Supreme Court]] lifted restrictions on corporation and union spending on politics. Individuals, corporations, and unions can now legally donate and spend unlimited amounts on independent political speech, as well as donate unlimited amounts to groups that make independent expenditures.<ref name="slate">[http://www.slate.com/articles/news_and_politics/politics/2012/03/the_supreme_court_s_citizens_united_decision_has_led_to_an_explosion_of_campaign_spending_.html ''Slate'' "The Numbers Don’t Lie," March 9, 2012]</ref><ref name="fred">[http://www.huffingtonpost.com/fred-wertheimer/citizens-united-and-contr_b_1291465.html ''Fred Wertheimer'' "Citizens United and Contributions to [[Super PAC]]s: A Little History Is in Order," February 21, 2012]</ref>
 
In 1976 the [[judgepedia:Supreme Court of the United States|U.S. Supreme Court]] held that individuals have the right to spend as much as they want on independent political messaging. Wealthy individuals could, and did, spend extensively on elections.<ref name="will"/> With two 2010 rulings, the [[judgepedia:Supreme Court of the United States|U.S. Supreme Court]] lifted restrictions on corporation and union spending on politics. Individuals, corporations, and unions can now legally donate and spend unlimited amounts on independent political speech, as well as donate unlimited amounts to groups that make independent expenditures.<ref name="slate">[http://www.slate.com/articles/news_and_politics/politics/2012/03/the_supreme_court_s_citizens_united_decision_has_led_to_an_explosion_of_campaign_spending_.html ''Slate'' "The Numbers Don’t Lie," March 9, 2012]</ref><ref name="fred">[http://www.huffingtonpost.com/fred-wertheimer/citizens-united-and-contr_b_1291465.html ''Fred Wertheimer'' "Citizens United and Contributions to [[Super PAC]]s: A Little History Is in Order," February 21, 2012]</ref>
  
During the [[Statewide elections, 2012|2012 elections]], [[Super PAC]]s are playing an increased role in the Presidential, [[U.S. Congress elections, 2012|congressional]], [[State executive official elections, 2012|State executive]] and [[State legislative elections, 2012|state legislative]] races.
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During the [[Statewide elections, 2012|2012 elections]], Super PACs are playing an increased role in the Presidential, [[U.S. Congress elections, 2012|congressional]], [[State executive official elections, 2012|State executive]] and [[State legislative elections, 2012|state legislative]] races.
==Distinction between PACs and super PACs==
+
==Distinction between PACs and Super PACs==
[[Super PAC]]s are not a subset of PACs, as their common name implies. The two types of groups are legally distinct, and different rules govern each.<ref name="at"/> [[Super PAC]]s are more accurately defined by their legal description: independent expenditure-only committees.<ref name="fec">[http://www.fec.gov/press/press2011/ieoc_alpha.shtml ''Federal Election Commission'' "Independent Expenditure-Only Committees," Accessed May 12, 2012]</ref>  
+
Super PACs are not a subset of PACs, as their common name implies. The two types of groups are legally distinct, and different rules govern each.<ref name="at"/> Super PACs are more accurately defined by their legal description: independent expenditure-only committees.<ref name="fec">[http://www.fec.gov/press/press2011/ieoc_alpha.shtml ''Federal Election Commission'' "Independent Expenditure-Only Committees," Accessed May 12, 2012]</ref>  
  
 
According to the Federal Election Commission:
 
According to the Federal Election Commission:
 
<blockquote>Independent expenditures represent spending by individuals, groups, political committees, corporations or unions expressly advocating the election or defeat of clearly identified federal candidates. These expenditures may not be made in concert or cooperation with, or at the request or suggestion of, a candidate, the candidate's campaign or a political party.<ref name="fec"/></blockquote>
 
<blockquote>Independent expenditures represent spending by individuals, groups, political committees, corporations or unions expressly advocating the election or defeat of clearly identified federal candidates. These expenditures may not be made in concert or cooperation with, or at the request or suggestion of, a candidate, the candidate's campaign or a political party.<ref name="fec"/></blockquote>
  
Unlike super PACs, traditional [[Political action committee|PACs]] have a $5,000 per person cap on donations and cannot accept money from corporations or unions. On the other hand, regular PACs may contribute directly to a politician or political party, whereas super PACs are limited to spending independently of such campaigns.<ref name="will">[http://www.washingtonpost.com/opinions/super-pacs-cant-crown-a-king/2012/02/28/gIQAAx0AjR_story.html ''George Will'' "[[Super PAC]]s can't crown a king'' February 29, 2012]</ref>
+
Unlike Super PACs, traditional [[Political action committee|PACs]] have a $5,000 per person cap on donations and cannot accept money from corporations or unions. On the other hand, regular PACs may contribute directly to a politician or political party, whereas Super PACs are limited to spending independently of such campaigns.<ref name="will">[http://www.washingtonpost.com/opinions/super-pacs-cant-crown-a-king/2012/02/28/gIQAAx0AjR_story.html ''George Will'' "[[Super PAC]]s can't crown a king'' February 29, 2012]</ref>
  
[[Super PAC]]s are also exempt from requirements to immediately report funding sources.<ref>[http://www.opensecrets.org/outsidespending/index.php ''OpenSecrets'' "Outside Spending," Accessed May 11, 2012]</ref>
+
Super PACs are also exempt from requirements to immediately report funding sources.<ref>[http://www.opensecrets.org/outsidespending/index.php ''OpenSecrets'' "Outside Spending," Accessed May 11, 2012]</ref>
  
 
==[[Super PAC]] spending==
 
==[[Super PAC]] spending==
 
===Hitting $100 million in 2012===
 
===Hitting $100 million in 2012===
As of mid-May 2012, super PACs had spent $100 million on the [[Statewide elections, 2012|2012 elections]]. This is over three times the amount spent by outside groups in the 2008 elections by this point, and $30 million more than the total outside spending in the 2004 elections.<ref name="osspend">[http://www.opensecrets.org/news/2012/05/super-pac-spending-teeters-at-100-million-mark.html ''OpenSecrets'' "[[Super PAC]] Spending Teeters at $100 Million Mark," May 10, 2012]</ref>
+
As of mid-May 2012, Super PACs had spent $100 million on the [[Statewide elections, 2012|2012 elections]]. This is over three times the amount spent by outside groups in the 2008 elections by this point, and $30 million more than the total outside spending in the 2004 elections.<ref name="osspend">[http://www.opensecrets.org/news/2012/05/super-pac-spending-teeters-at-100-million-mark.html ''OpenSecrets'' "[[Super PAC]] Spending Teeters at $100 Million Mark," May 10, 2012]</ref>
  
Conservative super PACS spent $91 million, compared to just $9 million by liberal super PACs. However, $86 million of the total was spent on the Republican presidential primary.<ref name="osspend"/> Due in part to a crowded presidential field on the GOP side, as well as some hotly contested congressional primaries, conservative super PACs vastly outspent liberal ones through May 2012.<ref name="huffpo">[http://www.huffingtonpost.com/2012/05/10/super-pacs-congress-races-conservatives_n_1507345.html?ref=politics ''Huffington Post'' "[[Super PAC]]s, Conservatives Lead Surge In Independent Spending On Congressional Races," May 10, 2012]</ref><ref name="osspend"/>
+
Conservative Super PACS spent $91 million, compared to just $9 million by liberal Super PACs. However, $86 million of the total was spent on the Republican presidential primary.<ref name="osspend"/> Due in part to a crowded presidential field on the GOP side, as well as some hotly contested congressional primaries, conservative Super PACs vastly outspent liberal ones through May 2012.<ref name="huffpo">[http://www.huffingtonpost.com/2012/05/10/super-pacs-congress-races-conservatives_n_1507345.html?ref=politics ''Huffington Post'' "[[Super PAC]]s, Conservatives Lead Surge In Independent Spending On Congressional Races," May 10, 2012]</ref><ref name="osspend"/>
  
 
====Lugar vs. Mourdock====
 
====Lugar vs. Mourdock====
Line 25: Line 25:
  
 
===Differing spending strategies===
 
===Differing spending strategies===
Conservative groups have focused on advertising in 2010 and so far in 2012<ref name="npr"/> -- a move that has been considered successful by its proponents.<ref name="lib">[http://www.nytimes.com/2012/05/08/us/politics/liberals-putting-super-pac-money-into-grass-roots.html ''New York Times'' "Liberals Steer Outside Money to Grass-Roots Organizing," May 7, 2012]</ref> As conservative independent groups have a significant funding advantage, some liberal super PACs are focusing on less-expensive means to compete -- mainly grassroots and voter-registration efforts. Democratic super PAC founder David Brock said he would not engage in "an arms race on advertising with the Republicans."<ref name="lib"/> Other liberal super PACs, however, have chosen to focus on advertising.<ref name="lib"/>
+
Conservative groups have focused on advertising in 2010 and so far in 2012<ref name="npr"/> -- a move that has been considered successful by its proponents.<ref name="lib">[http://www.nytimes.com/2012/05/08/us/politics/liberals-putting-super-pac-money-into-grass-roots.html ''New York Times'' "Liberals Steer Outside Money to Grass-Roots Organizing," May 7, 2012]</ref> As conservative independent groups had a significant funding advantage, some liberal Super PACs focused on less-expensive means to compete -- mainly grassroots and voter-registration efforts. Democratic Super PAC founder David Brock said he would not engage in "an arms race on advertising with the Republicans."<ref name="lib"/> Other liberal Super PACs, however, chose to focus on advertising.<ref name="lib"/>
  
 
==Younger voters forming Super PACs==
 
==Younger voters forming Super PACs==
In 2012, groups like Restore Our Future, [[American Crossroads]] and Priorities USA spent millions — reshaping the campaign landscape around the chase of big often older and male — donors. Now, America’s youth are ready and eager to get in on the game.<ref name="youth"/>
+
In 2012, groups like Restore Our Future, [[American Crossroads]] and Priorities USA spent millions — reshaping the campaign landscape around the chase of big, often older and male, donors.<ref name="youth"/>
  
 
In the month of August 2013, four super PACs were formed by people younger than 35 with the intention of advocating for young people. Often, the idea is to push back against political parties they say are drifting off course.<ref name="youth"/>
 
In the month of August 2013, four super PACs were formed by people younger than 35 with the intention of advocating for young people. Often, the idea is to push back against political parties they say are drifting off course.<ref name="youth"/>

Revision as of 11:47, 3 March 2014


Campaign Finance Ballotpedia.png

Super PACs

American Bridge 21st CenturyAmerican CrossroadsAmerican Unity PACCampaign for Primary AccountabilityClub for Growth ActionCongressional Leadership FundCooperative of American Physicians IE CommitteeCrossroads GenerationEnding Spending Action FundEndorse LibertyFair Share ActionFreedomWorks for AmericaGovernment Integrity FundHouse Majority PACIndependence USA FundLeague of Conservation VotersLiberty for All PACMajority PACNational Association of RealtorsNEA Advocacy FundNextGen Climate ActionNow or Never PACPlanned Parenthood VotesReady for HillaryRepublicans for a Prosperous AmericaRestore America's Voice PACSEIU Pea-FederalWomen Vote!Workers' Voice

A Super PAC is a political committee that has no legal limits on its spending or the donations it accepts. A Super PAC is not allowed to contribute directly to a politician or political party, but can spend independently to campaign for or against political figures. Hence, Super PACs are officially called independent expenditure-only committees.[1] Super PACs are not legally considered a kind of political action committee (PAC), which have separate rules governing their activities.[2]

In 1976 the U.S. Supreme Court held that individuals have the right to spend as much as they want on independent political messaging. Wealthy individuals could, and did, spend extensively on elections.[3] With two 2010 rulings, the U.S. Supreme Court lifted restrictions on corporation and union spending on politics. Individuals, corporations, and unions can now legally donate and spend unlimited amounts on independent political speech, as well as donate unlimited amounts to groups that make independent expenditures.[4][5]

During the 2012 elections, Super PACs are playing an increased role in the Presidential, congressional, State executive and state legislative races.

Distinction between PACs and Super PACs

Super PACs are not a subset of PACs, as their common name implies. The two types of groups are legally distinct, and different rules govern each.[2] Super PACs are more accurately defined by their legal description: independent expenditure-only committees.[6]

According to the Federal Election Commission:

Independent expenditures represent spending by individuals, groups, political committees, corporations or unions expressly advocating the election or defeat of clearly identified federal candidates. These expenditures may not be made in concert or cooperation with, or at the request or suggestion of, a candidate, the candidate's campaign or a political party.[6]

Unlike Super PACs, traditional PACs have a $5,000 per person cap on donations and cannot accept money from corporations or unions. On the other hand, regular PACs may contribute directly to a politician or political party, whereas Super PACs are limited to spending independently of such campaigns.[3]

Super PACs are also exempt from requirements to immediately report funding sources.[7]

Super PAC spending

Hitting $100 million in 2012

As of mid-May 2012, Super PACs had spent $100 million on the 2012 elections. This is over three times the amount spent by outside groups in the 2008 elections by this point, and $30 million more than the total outside spending in the 2004 elections.[8]

Conservative Super PACS spent $91 million, compared to just $9 million by liberal Super PACs. However, $86 million of the total was spent on the Republican presidential primary.[8] Due in part to a crowded presidential field on the GOP side, as well as some hotly contested congressional primaries, conservative Super PACs vastly outspent liberal ones through May 2012.[9][8]

Lugar vs. Mourdock

See also: United States Senate elections in Indiana, 2012

A major focus for conservative super PAC spending in spring 2012 was the Republican primary for Indiana's Senate seat. Independent groups poured $3.6 million into the race, with most seeking to boost state Treasurer Richard Mourdock over incumbent Richard Lugar. Super PACs like Club for Growth Action -- which spent $1.68 million on the race -- took credit for tea party favorite Mourdock's victory over establishment candidate Lugar.[9]

Differing spending strategies

Conservative groups have focused on advertising in 2010 and so far in 2012[10] -- a move that has been considered successful by its proponents.[11] As conservative independent groups had a significant funding advantage, some liberal Super PACs focused on less-expensive means to compete -- mainly grassroots and voter-registration efforts. Democratic Super PAC founder David Brock said he would not engage in "an arms race on advertising with the Republicans."[11] Other liberal Super PACs, however, chose to focus on advertising.[11]

Younger voters forming Super PACs

In 2012, groups like Restore Our Future, American Crossroads and Priorities USA spent millions — reshaping the campaign landscape around the chase of big, often older and male, donors.[12]

In the month of August 2013, four super PACs were formed by people younger than 35 with the intention of advocating for young people. Often, the idea is to push back against political parties they say are drifting off course.[12]

“When we’re talking about people our age, in their mid-20s to 30s, a lot of the candidates don’t represent exactly what we want,” said Sarah Ponn, 25, president of Pass the Torch PAC in Manchester, New Hampshire[12] Frustrated with what she sees as parties and politicians that are disinterested in the needs of young people, Ponn, 25, started a super PAC with two of her friends.[12] She says her group wants to re-brand the message of the Republican Party. They want to see the economy back on track, student loan rates fixed and politicians taking their focus off of social issues. “We’re trying to steer clear of issues like abortion and gay marriage,” she said. “With a lot of candidates … it’s hard to separate out what they really stand for and to get behind them for everything.[12]

“That’s why we went with a super PAC,” Ponn added. “It gives us that ability to step outside the party lines.”

It’s a sentiment young super PACs from both parties share: National candidates either don’t align with their views, or they don’t prioritize the issues that matter to them.[12]

For Brandon Anderson’s super PAC, Millenials for America, in Rock Island County, Illinois, those issues are achieving comprehensive immigration reform and reducing government intrusion in people’s lives; two things he says are important to the 20- and 30-somethings in his area.

“We’ve noticed that a lot of the younger people, even though most people around here identify as Democrats, when you actually ask them, they’re a lot more libertarian,” Anderson said. He hopes maybe his super PAC will help drum up some younger candidates to advocate for those issues, or at least lend a voice to the issues of an age group he thinks has been shut out of the political system.[12]

Ragheb Baio, 29, says he started Republican Youth for a Conservative Tomorrow PAC because he was tired of seeing the GOP put up presidential candidates that come off as close-minded and not relatable.[12] “Stupid things have been said, like legitimate rape, and Romney’s [47 percent] comments,” Baio said. “At this point, the youth vote and the minority vote have pretty much dismissed conservative views.”[12]

For other groups, like College Democrats of Ohio, forming a super PAC is about being in control of their money.[12]

Concerns about Super PACs

Disproportionate influence

As Super PAC spending rises, some worry that the Supreme Court has gone too far in making rulings that permit the flourishing of super PACs.[10] Fred Wertheimer, president of a nonprofit focused on campaign finance issues, wrote, "Unlimited contributions in federal elections invariably lead to corruption and scandal, and that is what is unfolding in the 2012 elections."[5] Political lawyer Ken Gross said, "The superPACs are metastasizing. ... I think it's very disturbing that the groups are bigger than the candidates and almost bigger than the party committees themselves."[10]

These concerns have been at play since the Citizens United case, with dissenting justices concerned about corporate money buying elections.[13] President Barack Obama called the decision a victory for "powerful interests that marshal their power every day in Washington to drown out the voices of everyday Americans."[13]

Close connections to candidates and parties

Some, including Senator John McCain, have raised concerns that many super PACs are not truly independent from candidates or parties.[14] Sometimes, a Super PAC will be founded by a former campaign manager of a candidate the Super PAC supports.[15][14] As Trevor Potter of the Campaign Legal Center said, "The candidate super PACs, what Mitt Romney has referred to as 'my super PAC,' are created by people closely associated with the candidates."[14]

Lack of disclosure

With the Federal Election Commission requiring only periodic reports from Super PACs, donors to a Super PAC's ad campaign may be hidden until after an election takes place.[16] Super PACs must submit a pre-election report 20 days before a primary it will be involved in, but between that report and the election, the Super PAC can wait until the next quarter ends before disclosing its finances.[16] Super PACs of all political bents say they are not trying to hide donor sources but merely complying with the FEC rules; however, a number of Super PACs have received the bulk of their contributions after the 20-day mark, meaning those donors will not be revealed until after the relevant primary.[16]

Paul Sherman of the Institute for Justice has argued, however, that after the reports do come in, "even among large-dollar donors, there are few surprises."[17]

Court decisions

Because of the complexity of campaign finance laws,[2] analysts disagree on which court decision was responsible for the rise of super PACs. Some, like columnist George Will, point out that citizens -- including wealthy individuals like George Soros -- have long been permitted to spend unlimited amounts on political speech.[3] Others, like elections law professor Richard Hasen, hold that the 2010 Citizens United ruling set the precedent for massive collaborative spending on elections, a precedent that was soon explicated in Speechnow.[4]

Buckley v. Valeo

In 1976, the U.S. Supreme Court ruled that the First Amendment protected individuals' right to spend unlimited amounts on political speech. The Court upheld caps on contributions to campaigns, but stated that restrictions on spending "relative to a clearly identified candidate" were unconstitutional.[18]

Citizens United

See also: Citizens United v. Federal Election Commission

In 2010, the U.S. Supreme Court ruled that the government cannot ban political spending by corporations or unions. Because these entities are "associations of citizens," the First Amendment right to free speech also applies to groups.[13]

In Citizens United v. Federal Election Commission, the Supreme Court considered federal laws that prohibited "corporations and unions from using their general treasury funds to make independent expenditures for speech defined as an “electioneering communication” or for speech expressly advocating the election or defeat of a candidate."[19]

In the majority opinion, Justice Anthony Kennedy wrote:

[W]ealthy individuals and unincorporated associations can spend unlimited amounts on independent

expenditures. ... Yet certain disfavored associations of citizens--those that have taken on the corporate form--are penalized for engaging in the same political speech.

When Government seeks to use its full power, including the criminal law, to command where a person may get his or her information or what distrusted source he or she may not hear, it uses censorship to control thought. This is unlawful. The First Amendment confirms the freedom to think for ourselves.[19]

Corporate spending after the decision

From a survey of 151 staffers of corporate and trade association PACs, election spending and directly political spending did not increase dramatically in the aftermath of the Citizens United decision. The survey concluded that 93% of corporations do not direct Super PACs or other political efforts. Trade associations engaged more in political spending, with 74% of trade associations not having any Super PACs or political activity through their association PACs. [20]

Speechnow v. FEC

Based partly on Citizens United, the U.S. Supreme Court ruled that since individuals and groups can spend unlimited amounts on independent political spending, they may also contribute unlimited amounts to committees that make such independent expenditures.[21]

A Federal Election Commission advisory opinion states:

Following Citizens United and SpeechNow, corporations, labor organizations, and political committees may make unlimited independent expenditures from their own funds, and individuals may pool unlimited funds in an independent expenditure-only political committee. It necessarily follows that corporations, labor organizations and political committees also may make unlimited contributions to organizations such as the Committee that make only independent expenditures.[22][21]

See also

External links

References

  1. New York Times "Who's Financing the 'Super PACs?" May 7, 2012
  2. 2.0 2.1 2.2 The Atlantic "The New York Times' Disingenuous Campaign Against Citizens United," February 24, 2012
  3. 3.0 3.1 3.2 George Will "Super PACs can't crown a king February 29, 2012
  4. 4.0 4.1 Slate "The Numbers Don’t Lie," March 9, 2012
  5. 5.0 5.1 Fred Wertheimer "Citizens United and Contributions to Super PACs: A Little History Is in Order," February 21, 2012
  6. 6.0 6.1 Federal Election Commission "Independent Expenditure-Only Committees," Accessed May 12, 2012
  7. OpenSecrets "Outside Spending," Accessed May 11, 2012
  8. 8.0 8.1 8.2 OpenSecrets "Super PAC Spending Teeters at $100 Million Mark," May 10, 2012
  9. 9.0 9.1 Huffington Post "Super PACs, Conservatives Lead Surge In Independent Spending On Congressional Races," May 10, 2012
  10. 10.0 10.1 10.2 NPR "As 'Citizens United' Turns 2, SuperPACs Draw Protests," January 20, 2012
  11. 11.0 11.1 11.2 New York Times "Liberals Steer Outside Money to Grass-Roots Organizing," May 7, 2012
  12. 12.0 12.1 12.2 12.3 12.4 12.5 12.6 12.7 12.8 12.9 Politico, "20-somethings jump into super PACs," accessed August 26, 2013
  13. 13.0 13.1 13.2 New York Times "Justices, 5-4, Reject Corporate Spending Limit," January 21, 2010
  14. 14.0 14.1 14.2 Brookings Institution "Campaign Finance in the 2012 Elections: The rise of the Super PACs," March 1, 2012
  15. The Daily Beast "McCain Rips Super PACs," March 27, 2012
  16. 16.0 16.1 16.2 Open Secrets "Stealthy Super PACs Influenced Primaries Without Disclosing Donors," July 2, 2012
  17. Washington Times "SHERMAN: Time to relax about super PAC disclosure," February 27, 2012
  18. Cornell University Law School "Buckley v. Valeo," January 30, 1976
  19. 19.0 19.1 Supreme Court "Opinion 08-205," Accessed May 11, 2012
  20. Politico, "Survey: Corporations still shun super PACs," Accessed June 21, 2013.
  21. 21.0 21.1 New York Times blog "Big-Dollar Individual Campaign Giving and the Tie to Citizens United," March 2, 2012
  22. Federal Election Commission "Advisory Opinion 2010-11," July 22, 2010