individuals and groups to make certain kinds of political donations and they ban certain kinds of advertising in the

months leading up to an election. Some called these bans into question after the release of two films: Michael

Moore’s Fahrenheit 9/11and Citizens United’s Hillary: The Movie. At question was whether each film sought to
438 18 • Public Economy

discredit political candidates for office too close to an election, in violation of the BCRA. The lower courts found that

Moore’s film did not violate the Act, while Citizens United’s did. The fight reached the Supreme Court, as Citizens

United v. Federal Election Commission, saying that the First Amendment protects the rights of corporations as well

as individuals to donate to political campaigns. The Court ruled, in a 5–4 decision, that the spending limits were

unconstitutional. This controversial decision, which essentially allows unlimited contributions by corporations to
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