Fifteen years later, Citizens United defined the 2024 Election

Jan 23, 2025 Story by: Editor

Fifteen years ago, the Supreme Court handed down its controversial decision in Citizens United v. Federal Election Commission , overturning more than a century of campaign finance laws. Justice Ruth Bader Ginsburg described it as the "worst ruling" of her tenure. Since then, overwhelming majorities of Americans have expressed disapproval of the decision, with at least 22 states and hundreds of cities supporting constitutional amendments to reverse it.

The Citizens United ruling dramatically reshaped political campaigns in the United States. It allowed corporations and billionaire-funded super PACs to dominate elections and unleashed a flood of untraceable “dark money” into politics. While its impact has been felt for over a decade, the aftermath of the 2024 election provides new insights into the case's far-reaching consequences.

Transforming Campaign Spending

Initially framed as a case about corporate free speech, Citizens United essentially dismantled most restrictions on independent political spending — funds spent on elections without being directly coordinated with candidates or parties. This gave rise to super PACs, organizations that can raise and spend unlimited sums as long as they maintain some formal separation from campaigns.

These super PACs, funded by a small group of ultra-wealthy donors and special interest groups, now wield enormous political influence. The 2024 election revealed just how deeply they have embedded themselves in American politics, not just through advertising but also by taking over essential campaign activities like door-to-door canvassing and voter outreach — efforts that would have been illegal before the decision.

The Role of Big Money in the 2024 Election

Donald Trump’s 2024 presidential campaign demonstrated the profound effects of Citizens United . Despite trailing Kamala Harris in traditional campaign donations — which remain subject to legal limits and disclosure rules — Trump relied heavily on super PACs and other outside groups funded by wealthy donors to bridge the gap.

Notably, Elon Musk, the world’s richest person and owner of X (formerly Twitter), played a pivotal role in Trump’s campaign. Musk donated at least $277 million to pro-Trump super PACs and became actively involved in campaign operations, even meeting with world leaders and influencing policy during the transition period. One super PAC Musk supported funded voter outreach efforts in key swing states, while another ran ads defending Trump’s record on abortion.

Trump’s reliance on billionaire donors extended beyond Musk. Others, such as venture capitalist David Sacks, casino magnate Miriam Adelson, and packaging tycoon Richard Uihlein, collectively funneled hundreds of millions of dollars into pro-Trump super PACs. This allowed Trump to run a lean campaign with minimal staffing, while Harris’s campaign employed over 2,500 people in battleground states.

While Harris also benefited from billionaire backers, including tech figures like Dustin Moskovitz and Bill Gates, their involvement appeared less central to her campaign’s operations.

The Growing Influence of Dark Money

The 2024 election also saw record-breaking levels of outside spending in congressional races, with most of the funds coming from out-of-state donors. National super PACs often outspent candidates themselves, shaping key races in states like Arizona, Pennsylvania, and Ohio. For instance, Ohio’s Republican Senate primary attracted over $20 million in independent spending, mostly from donors in other states.

Dark money — funds from groups that are not required to disclose their donors — also continued to proliferate, making it harder to trace the sources of campaign spending.

The Legacy of Citizens United

The Citizens United decision and subsequent rulings, such as McCutcheon v. FEC in 2014 , have fundamentally altered the landscape of campaign finance. While the Court upheld certain safeguards, such as transparency rules, these protections have been undermined by weak enforcement and regulatory loopholes. The Federal Election Commission (FEC), for example, has failed to address many complaints about dark money or enforce rules against coordination between candidates and super PACs.

Congress, too, has struggled to pass meaningful reforms. Efforts to enhance transparency, strengthen FEC enforcement, and establish public financing systems have repeatedly stalled.

As a result, the wealthiest donors remain at the center of U.S. campaigns, influencing not only elections but also governance. The 2024 race highlighted how Citizens United has allowed a small group of billionaires to reshape the democratic process , raising urgent questions about the future of campaign finance reform.

How Citizens United Took Shape

The Citizens United case began when a conservative nonprofit challenged campaign finance rules preventing it from promoting a film critical of Hillary Clinton before the 2008 Democratic primaries. Instead of issuing a narrow ruling, the Supreme Court’s 5-4 majority struck down virtually all limits on independent political spending by corporations and outside groups, citing the First Amendment.

This decision built on the Court’s 1976 ruling in Buckley v. Valeo , which equated campaign expenditures with free speech while allowing some limits on direct donations to candidates. In 2003, the Court upheld certain campaign finance rules in McConnell v. FEC , but Citizens United reversed key aspects of that decision, paving the way for unlimited spending by super PACs.

By eliminating aggregate donation limits in McCutcheon , the Court further expanded the influence of wealthy donors. These decisions, coupled with weak regulatory enforcement, have entrenched big money in American politics, raising concerns about corruption and the erosion of democratic principles. Source: Brennan Center