Citizens United v. Federal Election Commission has often been credited for the creation of "super PACs", political action committees which make no contributions to candidates or parties and so can accept unlimited contributions from individuals, corporations and unions. Certainly, the holding in Citizens United that, for purposes of establishing a "compelling government interest" of corruption sufficient to justify government limitations on political speech, "independent expenditures, including those made by corporations, do not give rise to corruption or the appearance of corruption", helped affirm the legal basis for super PACs. However, it took another decision by the U.S. Court of Appeals for the District of Columbia Circuit, Speechnow.org v. Federal Election Commission, to actually authorize the creation of super PACs. While Citizens United held that corporations and unions could make independent expenditures, a separate provision of the Federal Election Campaign Act, at least as long interpreted by the Federal Election Commission, held that individuals could not contribute to a common fund without it becoming a PAC. PACs, in turn, were not allowed to accept corporate or union contributions of any size or to accept individual contributions in excess of $5000. In Speechnow.org, the D.C. Circuit, sitting en banc, held 9–0 that in light of Citizens United, such restrictions on the sources and size of contributions could not apply to an organization that made only independent expenditures in support of or opposition to a candidate, but not contributions to a candidate's campaign. The effectiveness of this system remains a hot topic in American politics. See Political Action Committee.
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