How did Austin v. Michigan Chamber of Commerce influence campaign-finance law before Citizens United?

Before the Supreme Court's 2010 ruling in Citizens United v. Federal Election Commission, the 1990 decision in Austin v. Michigan Chamber of Commerce served as a foundational precedent for campaign-finance law.12

In Austin, the Court held that the government could constitutionally prohibit corporations from using their general treasury funds for independent political expenditures. The ruling was based on the state’s interest in preventing corporations from "distorting" the political process and reducing the potential for corruption or the appearance of corruption.2

This precedent was significant because it allowed the government to assign different free-speech rights to speakers based on their identity as corporate or individual entities. Furthermore, Austin provided the legal justification for the Supreme Court’s later decision in McConnell v. Federal Election Commission (2003), which upheld Section 203 of the Bipartisan Campaign Reform Act (BCRA). By relying on Austin, the Court had previously affirmed that restrictions on corporate electioneering communications were constitutional.32

Ultimately, the Citizens United majority overruled Austin, rejecting the "antidistortion" interest as a sufficient justification for limiting corporate political speech.3