How did the SpeechNOW.org v. Federal Election Commission decision build on Citizens United?

The decision in SpeechNOW.org v. Federal Election Commission (2010) built directly upon the U.S. Supreme Court’s ruling in Citizens United v. Federal Election Commission by extending the logic regarding independent expenditures to individual contributions.12

While Citizens United established that the government could not constitutionally limit independent political expenditures by corporations and unions, the D.C. Circuit Court of Appeals applied this reasoning in SpeechNOW to strike down Federal Election Campaign Act (FECA) limits on the amounts individuals could contribute to organizations that engage exclusively in independent expenditures.12

By ruling that these contribution limits were unconstitutional, the SpeechNOW decision facilitated the emergence of "Super PACs"—political action committees that can accept unlimited contributions from individuals, corporations, and unions to spend on independent advocacy. Although the court in SpeechNOW upheld disclosure-and-identification requirements, the combined effect of these two rulings fundamentally transformed the landscape of campaign finance by allowing for massive, unlimited influxes of money into federal elections.12