Why Media Corporations Lie About Citizens United,
and How to Get Money out of Politics
By Wendy Joy Welsh
HelpUncleSam.org | September 12th, 2014
I don’t have to scream “Wake up!” Most people are aware that there is a problem with our government. The only people who don’t see a problem are so busy working that they just don’t have the time to notice that our standard of living has taken a nosedive.
Those hard working folks say, “Everything is fine. Just work hard and save.” Merely putting your head down and working hard is good advice when you are not at war, but we are at war. It is an old war. So old that a man born in 1469 wrote about it. Machiavelli wrote that a government is either created for the people or for the “the aristocracy. For in every city these two opposite parties are to-be found, arising from the desire of the populace to avoid the oppression of the great, and the desire of the great to command and oppress the people.” It is remarkable that someone from so long ago would describe the main conflict that we are experiencing today: the 1% oppressing the 99%.
We have won many battles in this war in order to have the lifestyle we enjoy today. During the Industrial Revolution, people couldn’t “just work hard and save” because the amount of money they received in exchange for their labor was not enough to live. They also couldn’t simply work more; they worked about 14-16 hours a day. Thanks to the workers of that time who stood up to fight the oppression our lives are better, but the war is not over. Today foreign labor is being exploited with “15 to 19” hour days and child labor. This is not only bad for foreign workers, but US jobs are lost to that exploitation. The 1%’s exploitation of foreign labor is making it harder and harder every day for US workers to “just work hard and save.”
The People’s Greatest Weapon
The 1%’s greatest weapon is money, and the people’s greatest weapon is their ability to form a group. Understandably, it would be in the 1%’s best interest to render the peoples’ groups powerless, and the 1% have spent a lot of energy trying to accomplish just that. With the conservative media-corporations they demonize the unions. The conservative Media paints unions as wasteful inhibitors that insist, “Only union-guys can pick up boxes or turn on lights.” To that I would say, “bad mothers exist, but that does not make mothering bad” and “we still have to be thankful to the unions for our 8 hour days and decent wages.” With liberal media-corporations they demonize corporations in general. The liberal Media insists that corporations are inherently destructive to the American people, but corporations are not just the 1%’s mega corporations.
The Red Cross, Sierra Club, Greenpeace, ACLU, NAACP, and most non-profits, churches, and unions are corporations. Corporations are a necessary legal fiction, For example it allows someone to join the Sierra Club, but not be liable for damages if the Sierra Club does anything wrong, and if a corporations does do something wrong, this legal fiction can be brought to court for damages.
Over the past few years, the 1% have been endorsing a way to get money out of politics that silences all organizations except their media corporations. They have created the catchy slogan “Corporations Aren’t People” which grows nicely in the anti-corporation fertile ground. Hope lives in those three words, a hope that we, the people, can finally tame the mega corporations. But taking away the rights of corporations will not affect the mega corporations. The mega corporations don’t need protection under the Constitution. With their money and lobbyists they are not only above the law, they write the law. With what power can the people gain control over the mega corporations when our means to collect together and mobilize is impaired?
Attacking unions and deceiving us is not a new tactic of the 1%. Speaking about the right-to-work laws in 1961, Reverend Martin Luther King Jr. said, “In our glorious fight for civil rights, we must guard against being fooled by false slogans, such as ‘right to work.’ It is a law to rob us of our civil rights and job rights. Its purpose is to destroy labor unions and the freedom of collective bargaining by which unions have improved wages and working conditions of everyone… We demand this fraud be stopped.” Right now the citizens are being deceived by the “Corporations Aren’t People” slogan. It intends to undermine unions and non-profits. When Martin Luther King Jr. said, “freedom of collective bargaining” he was talking about the freedom of collections of people, and collections of people are legally considered corporations.
To fight deception we need knowledge. We will explore what the 1%’s goals are and what is at stake if they reverse Citizens United, or worse amend the Constitution to say that corporations aren’t people. Getting money out of politics is extremely important, so we will carefully examine how money influences our politicians and give options on how to get the 1%’s money out of politics in a way that doesn’t go against the fundamental interests of the American people.
How Does Money Buy Politicians?
The revolving door is a method that some lawmakers use to become millionaires. The legislators use their time in Congress as a job interview (of sorts) for a more lucrative position working for the corporations who financed them. Upon leaving office they get a position as a lobbyist or on the board of one of their campaign contributor’s companies. These former congressmen make on average a 1,452 percent increase in salary when they become lobbyists. This corruption doesn’t just come from one party. Both Republicans and Democrats do this.There are laws that prohibit legislators from lobbying one or two years after leaving office, but this has not stopped the payoff. The former legislators “are often hired by lobbying firms as consultants or advisors immediately upon leaving Congress, and then begin lobbying once the year-long ‘cooling off’ period is over.”
We think that the legislators are doing a bad job. I would argue that they are doing a great job, but they are not working for us. It’s pretty obvious that these former congressmen are being paid off for the services that they performed while in office. For example former Congressman Billy Tauzin (R-LA) went to work at the pharmaceutical lobbying firm: PhRMA. As a congressman Tauzin helped his future clients by blocking “a proposal to allow Medicare to negotiate for drug prices, a major concession that extended the policies enacted in Tauzin’s original Medicare drug-purchasing scheme. Tauzin left PhRMA in late 2010. He was paid over $11 million in his last year at the trade group.”10 These high salaries paid to the former congressmen do not only serve as a payoff. These salaries are an advertisement to the current congressmen that the 1% will honor their secret deals.
$11 million seems high for a yearly salary, but my guess is that the $11 million was a small percentage of the money the 1% collected or “saved” by the laws that this congressman passed. It would be really interesting to find out how much the pharmaceutical companies made from the laws that Tauzin passed. That would help us see how much a congressman is worth, worth to us and to the 1%. Luckily three professors at the University of Kansas calculated the average rate of return on lobbying dollars. Their research gives us an idea of what kind of money is at stake. The study “examined the impact of a one-time tax break approved by Congress in 2004 that allowed multinational corporations to ‘repatriate’ profits earned overseas, effectively reducing their tax rate on the money from 35 percent to 5.25 percent. More than 800 companies took advantage of the legislation, saving an estimated $100 billion in the process.” “The researchers calculated an average rate of return of 22,000 percent for those companies that helped lobby for the tax break.”13
The estimated $100 billion that was “saved” should have gone into our government. We all pay for roads and infrastructure, but these corporations are perfectly happy to have the taxpayers shoulder the burden of infrastructure or to increase our national debt so our children will carry that burden. The scariest part is that was just one law. We think so small. We argue about paying legislators $174K when the laws they pass can either sink us or keep us afloat. The 1% knows what legislators are worth. The real market value for a legislator is in the millions. The $174K salary that we pay legislators is chump change. Compare that to the $9 million for a senatorial seat with the McCain-Feingold Act. These are not our lawmakers. They are the 1%’s lawmakers. If this one law cost us $100 billion imagine the trillions that are being lost every year by legislators writing laws for the 1%.
How to Stop Corruption
In order to stop corruption we need to elect lawmakers who make laws that are good for the people not laws that benefit the legislator’s future employers. So, how do we change the election process to select the honorable instead of the duplicitous? The media corporations say that campaign finance (donations to pay for campaigning) is the “root” cause of corruption in our government. “At newspapers all across the country and (nearly) all across the political spectrum, editorial boards are expressing profound alarm at the outsized effect of money on the political process, particularly since the Supreme Court … January 2010 Citizens United ruling.” They assert that overturning a Supreme Court ruling called Citizens United will stop the buying of our legislators. But reversing Citizens United has no effect on the revolving door. Since the revolving door is the most likely vehicle for “buying” our politicians, it is misguided to believe that reversing Citizens United is the answer to our corruption problems. This is the media corporations’ little white lie, but just wait this little white lie gets much, much larger.
The McCain-Feingold Act
The McCain-Feingold Act is at the heart of the Supreme Court’s Citizens United ruling. Reversing Citizens United means insisting that we use the McCain-Feingold Act. Senators John McCain (R-AZ) and Russ Feingold (D-WI) tried to solve the campaign finance problem by creating the 2002 McCain-Feingold Act (aka Bipartisan Reform Act). At the time, we were under the assumption that the biggest spender won most elections. The idea was that paid TV ads were swaying the public and hence “buying” the election. The McCain-Feingold Act called for “electioneering communications” to be illegal, and with that prohibited outside groups like political action committees (PACs), corporations, and non-profit organizations from buying ads that name a candidate 30 days before a primary and 60 days before a general election.
At first glance the McCain-Feingold Act seems really great. Political action committees have so much money. They buy ads that flood the TV, and with those ads influence our voters. If we stop allowing the PACs to buy airtime for a few months before an election, there will be a moment of peace where voters can contemplate each candidate and decide for themselves, which is the best.
This McCain-Feingold Act sounds good, but I’ll give you two reasons why the McCain-Feingold Act isn’t the solution we were hoping for. First, it is not solving the campaign finance issue. During the time the McCain-Feingold Act was instituted, the cost of elections was still high enough to be a breeding ground for corruption. Secondly, there really isn’t that “moment of peace.” While everyone else is forbidden to speak, the media corporations are still allowed to sway the public.
Reason #1: Why the McCain-Feingold Act doesn’t work:
It cannot “end corruption.”
The McCain-Feingold Act was in effect from 2002 to 2010. If the McCain-Feingold Act could get corruption out of our government, then the cost of winning an election during that time period should be reasonable. If you look at the table at the end of this article, you will see that between 2002-1010 candidates needed to raise an average of over one million dollars to become a member of the House of Representatives and around nine million dollars to become a Senator[i].
Yes, allowing PACs to buy ads increases the amount of money involved, but the situation is defective with or without the McCain-Feingold Act. Whether it costs millions (without PACs) or billions (with PACs) our democratic republic is still up for sale. The McCain-Feingold Act is like a Band-Aid on a fatal laceration. Our democracy will still bleed to death with the Band-Aid.
Reason #2: Why the McCain-Feingold Act doesn’t work:
We are only allowed to hear the opinions of the Media.
We were expecting that the McCain-Feingold Act would prevent voters from being influenced by corporate funds, but it is doing just the opposite. The strongest voice of the corporations is the Media (newspapers and TV on both the Left and the Right). The CEO of Westinghouse (CBS) was completely clear about whose interests he serves when he said, “We are here to serve advertisers. That is our raison d’etre.” The Media is not only greatly influenced by the companies, which supply advertising dollars, but also the Media is “either linked to, or outright owned by, much bigger corporations.” Corporations determine what we hear and read via the Media.
The Media is exempt from the restrictions of the McCain-Feingold Act. Under the McCain-Feingold Act, the Media is the only collection of people allowed to sway the public30 days before a primary and 60 days before a general election.With the McCain-Feingold Act these media corporations are allowed to speak, but a nonprofit is not. I find it ironic that people are saying, “Corporations aren’t People” in the effort to give more rights to the media corporations. Prohibiting people from gathering together their resources to influence their fellow citizens sets a rather Orwellian stage: It is illegal for a group of people to speak! Only the Media is allowed to speak!
Many people are advocating Lessig’s Democracy Voucher system (where citizens give vouchers to the candidate of their choice) and the Clean Money Clean Elections system (where the candidates are all given the same amount of money to campaign with). In both of these systems all of the candidates would be working with a fair and just amount of influence time, all except for the 1%’s candidates. Just as it does today, the Media would dispense as much influence as it can pack into every news program, talk show, and even comedy show.
Let’s get to the Supreme Court case called Citizens United vs. FEC. Citizens United is a nonprofit organization. Citizens United made a movie called “Hillary: The movie.” The people at Citizens United must really hate Hillary Clinton because this movie is extremely unflattering. In their efforts to cripple Mrs. Clinton’s bid at the 2008 Democratic primary, Citizens United attempted to air their movie right before that election. These efforts led them to this Supreme Court case. Airing their movie and the ads for their pay per-view movie, shortly before an election, was in violation of the McCain-Feingold Act.
The Federal Election Commission and Citizens United went before the Supreme Court in a case that is commonly referred to as the “Citizens United” case. The FEC accused Citizens United of violating the McCain-Feingold Act. What is important to note is that the Constitution states that Congress is not allowed to make laws which prohibit the speech of the people, and that the Constitution also refers to collections of people, like corporations and non-profits, just the same as individual people. The Supreme Court reasoned that since Citizens United is considered a person, prohibiting it from communicating with the public is prohibiting speech, which goes against the First Amendment. The Supreme Court deemed that the McCain-Feingold Act was unconstitutional.
At a dinner in 2012, US Supreme Court Associate Justice Samuel Alito Jr. defended the Citizens United decision. “The question is whether speech that goes to the very heart of government should be limited to certain preferred corporations; namely, media corporations,” he said. “Surely the idea that the First Amendment protects only certain privileged voices should be disturbing to anybody who believes in free speech.”
The media corporations want to reverse the Citizens United ruling. They spin the facts to make people think that reversing Citizens United will make our elections “clean” and our country better for “natural” people, but in reality reversing Citizens United is merely demanding that we use the McCain-Feingold Act which will at best not make enough of a change (Reason #1: It will still cost millions of dollars to become a Senator) and at worst will leave us at an even greater disadvantage (Reason #2: Only media corporations will be allowed to sway the public around election time).
Knowingly Misguiding the Public
After the Citizens United decision, the media corporations began a smear campaign against the decision. They implied falsehoods and blamed widespread corruption on this decision. In Dan Abrams’s article “The Media’s Shameful, Inexcusable Distortions of the Supreme Court’s Citizens United Decision” he says, “reading the New York Times, Washington Post and watching MSNBC in particular, it is hardly surprising that the public would be confused” because of “the widespread misinformation by the media about what the court actually considered and ultimately ruled.” The Atlantic article entitled “The New York Times’ Disingenuous Campaign Against Citizens United” covers the discrepancy between the Media’s misrepresentation of the decision and many expert opinions: “Mistakes about Citizens United are beginning to look more like propaganda, because even after being alerted to its misstatements, the Times has continued to repeat them.” The Media knowingly lied to the public.
Could it be that the media corporations are acting in the interest of profit only and that the disregard to truth is just a byproduct of that desire for profit? No, it is just the opposite. When the media corporations demand the use of the McCain-Feingold Act, they are demanding a restriction of their market. With the McCain-Feingold Act they are not allowed to sell ads to groups mentioning a candidate around election time. Media corporations would make significantly more profit without the McCain-Feingold Act. Since the media corporations have been notified of their misrepresentation of the Citizens United decision, and lying about Citizens United hurts corporate profits, it is safe to say that the goal of the media corporations is not merely to make profits with ads. This is significant. These are clear signs of propaganda.
So, what would the 1% have to gain from lying about Citizens United? First off, public opinion controls a democracy. Anyone who can control public opinion can control that democracy. Silencing citizens’ organizations ensures that the media corporations have a monopoly on voter influence during the critical election time. Secondly, lying about Citizens United has segued into amending the Constitution. Keep in mind that the 1%’s greatest weapon is money and the people’s greatest weapon is their ability to collect together in a group. Amending the Constitution to take away the rights of corporations could eviscerate our organizations.
Could the Constitution be wrong in declaring that collections of people should have the same rights as non-collected people? Perhaps. Lumping corporations and citizens under the same category in order to define collective rights seems like an inelegant solution, but at this point in time this “legal personality” is one of the five core structural characteristics that make up the backbone of corporate law. Legal personality allows corporations to engage in contracts “permitting the firm to serve as a single contracting party.”21 This helps corporations to be held accountable and be sued or to sue. Legal personality also secures the “firm’s rights of ownership over its designated assets”21 including the rights to use the assets and to sell them.
Corporate law doesn’t just give rights to the mega corporations. Corporate law also gives the rights to all collections of people, like unions and non-profits. I’m sure that if you and your friends made a local organization, you wouldn’t be too happy if someone arbitrarily took your assets whether those assets were office equipment or your pooled money. Without rights what would prevent the 1% from liquidating our non-profits, unions, or small businesses?
If we amend the Constitution to define corporations as non-people, that would either lead to our unions and non-profits having no rights or to the legislators having to create new laws defining the rights of organizations. If our current Congress and Senate were set to the task of drafting laws to govern corporations, it would be like handing a pen to the 1% to draft laws governing not only their corporations, but perhaps even more importantly our organizations. Any laws coming out of this legislative body would be more favorable to the 1% than our existing laws. So I beg you: Please do not amend the Constitution, at least not now.
The question “How do we change the election process to select the honorable instead of the duplicitous?” still needs to be answered. In my opinion the problem is not with democracy; it is with our implementation of it. We need to recreate this democratic republic in the image of what we have all believed it was: rule by the people. We need to design a system knowing that any one participant could be or become corrupt. Our scientists and engineers have accomplished feats that boggle the imagination. This problem is simple in comparison. We need to open up a discussion of possible solutions, and to investigate, suggest, and weigh new methods in order to come up with a system of government that could actually be called a democracy. Since it is important to get some real solutions on the table as soon as possible, I will offer two methods right now.
To those uncomfortable with fundamental change, who might say change is “un-American” take a look at where our country stands today. With so much corruption starvation is a reality in the United States. Wealthy mothers in China can now say to their children, “Eat your vegetables. There are some starving children in America who would love to eat that.”Also, in our current state of corruption the US is not a capitalist country. The benefits of capitalism come from businesses succeeding by being good at supplying products that people want. When corruption gives the mega corporations many unfair advantages with subsidies and tax breaks, those corporations don’t have to do good work in order to succeed, which in turn makes it hard for honest businesses. What we have now is more un-American than we want to admit.
Comprehensive Legislative Trust
We are worried about how much money goes into the system, but perhaps the payoff that should concern us more. To stop corruption, stop the pay off. Becoming a Congressman or Senator should not be a ticket to becoming a millionaire, and it would be conspicuous if a candidate would not put that in writing. If an elected official wants to make this country a better place, and not just pad his pocketbook, then he should be more than willing to sign a contract that forbids him from using this position to become a millionaire.
I suggest that we institute a type of financial trust that is quite a bit more comprehensive than the financial trusts that some congressmen currently use. 1. It should be a lifelong trust. There are US soldiers who die to keep our country free. I don’t think it is too much to ask a legislator to give up her monetary autonomy for her entire life in order to keep our country free. Also, it is a choice. If someone doesn’t want to give up her monetary autonomy then she should not apply for office. 2. Give legislators a comfortable living for life, not lavish but comfortable. 3. After the congressmen leave office give them the simple assignment to help our country in any way they can. 4. Setup an award system to periodically honor former congressmen who make remarkable contributions that boost our standard of living and economy. With the Comprehensive Legislative Trust we can make the former congress our heroes instead of the 1%’s heroes.
Things are often labeled “good” only because they are familiar, but when taken out of a familiar context, they can be seen for what they really are. Before I explain to you my second method of battling corruption, take a moment to imagine a world where being a court juror is a paid position just like a congressman. Imagine a world where jurors are “elected” instead of just randomly selected. Juror candidates would put effort into getting themselves elected, by taking out TV ads just like the congressional candidates do. To reach the public these juror candidates would need money for ads and for election costs. Any person or corporation who is interested in the outcome of a case could make a private agreement with a potential juror and then financially back their campaign. It wouldn’t be surprising if some of the jurors, especially of high profile cases, ended up as millionaires. Would that juror election process be working for justice or is it working for money?
Working for justice should be the goal for both jurors and legislators. Jurors have to decide cases based on the laws. Legislators have to decide what those laws are. The NPR piece called “Take the Money and Run for Office” states, “Barney Frank and lots of others told us straight up: A lot of times the lobbyist knows much more about your subject than you do. As a congressman you depend on their expertise and so you listen to their arguments. The problem is those arguments are accompanied by a large check.” What we expect of legislators is that they are experts. Clearly, by their own admission they are not experts. The laws they are passing, which hurt our economy and country, show that the legislators are either corrupted or simply not experts.
One could argue that random selection might be better than the election process we have now, but whatever we do there needs to be change. I suggest that we use a method I call Honorable Elections, which simplifies the campaigning process and works for justice not for money. Honorable Elections whittles elections down to a series of one-week sub-elections, and finds the best candidate in the same way sporting competitions find the best team. The elections start in towns and move out to larger and larger districts. We don’t need to see candidates or shake their hands. We just need to hear what they have to say about themselves and watch them debate.
Honorable Elections: Step 1. Setup Campaign: a. Get Signatures: Let anyone who is interested in being a legislator get the number of signatures required (this will weed out the ridiculous candidates). b. Submit Campaign: Have those candidates submit both in writing and in video their reasons for running. We will call this: the candidate’s “campaign”. Step 2. Local Voting: a. Post each candidate’s campaign on his or her town web site. b. Allow one week for people to visit the local candidates’ sites, view the material, and vote. c. Local Debate and Final Vote: Hold a debate with the top three candidates (winners of the most votes). Post the video and transcript of the debate, and take another vote a week later to decide the winner in that town. Step 3. District Voting: a. The winners of each town are posted on that town’s district’s site. Allow one week for people to view the district candidates’ campaigns and another vote is taken. b. Allow one week for people to visit the district candidates’ sites, view the material, and vote. c. District Debate and Final Vote: Hold a debate with the top three candidates, those who won the most votes, and hold a final vote.
With Honorable Elections there is no money involved in campaigns. Elections would be based on information instead of smear, spin, and party loyalty. Best of all, it frees the legislators to actually do their job. Right now legislators spend half of their workday campaigning for their next election. Senator Dick Durbin on NPR’s Planet Money said, “I think most Americans would be shocked – not surprised, but shocked – if they knew how much time a United States Senator spends raising money. And how much time we spend talking about raising money, and thinking about raising money, and planning to raise money, and, you know, going off on little retreats and conjuring up new ideas on how to raise money.” The DCCC — the campaign arm of the House Democrats – expects its incoming freshmen from the minute they are elected to spend half of their time raising funds, and I would bet the Republicans have the same expectation.
I personally would like to see both the Comprehensive Legislative Trust and the Honorable Elections instituted, but I must reiterate that these two ideas are not the only options to battle corruption. For example, we could even make this a full-fledged democracy instead of a democratic republic and have all of the laws posted on a forum for people to vote on. There are a lot of options at our fingertips. The media corporations imply that reversing Citizens United is the only way to get money out of politics, but understand that this is simply not true.
We should be standing up against the 1% with our heads held high, proudly holding our shield emblazoned with the words “US Constitution and Bill of Rights,” and brandishing our sword of unity, but instead we are attacking our own sword and shield. We are led to do so by the 1%’s media corporations. Stop believing the media corporations, and don’t let them amend the Constitution! It goes without saying that “Media Corporations Aren’t People Either” and that our corporations need rights whether they are non-profits, unions, or even our small businesses. Create or find methods that get money out of politics, which don’t go against the fundamental interests of the people, and support the method that makes the most sense to you. I will post my methods and other ideas at HelpUncleSam.org.
Don’t forget that we are at war. We must put aside some time every week to fight this battle. We are lucky that we do not have to fight this battle while working 15 hours a day, which might be what our descendants will have to do if we don’t act. I will leave you with the words of the great Reverend Martin Luther King Jr.: “We are confronted by powerful forces telling us to rely on the goodwill and understanding of those who profit by exploiting us. They deplore our discontent, they resent our will to organize… we know that if we are not simultaneously organizing our strength we will have no means to move forward. If we do not advance, the crushing burden of centuries of neglect and economic deprivation will destroy our will, our spirits and our hope.”
 “The Prince” (Chapter IX Concerning A Civil Principality), Nicolo Machiavelli 1513
 “Blood & Exhaustion Behind Bargain”, China Labor Watch https://www.chinalaborwatch.org/pro/proshow-121.html
 “Child labour uncovered in Apple’s supply chain,” Juliette Garside Jan 25, 2013 The Guardian
 “Should Churches Be Incorporated?”, Baptist Legal Update, Sept 18, 2006, http://baptistlaw.blogspot.com/2006/09/should-churches-be-incorporated.html
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 “When a Congressman Becomes a Lobbyist, He Gets a 1,452 Percent Raise (On Average)” by Lee Fang, The Nation, March 14, 2012
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 “FORMER MEMBERS TURNED LOBBYISTS”, Open Secrets, http://www.opensecrets.org/lobby/lobby00/former.php
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 “Citizens United Seen As Root Of Evils By Editorial Writers Across Country,” by Dan Froomkin 1/10/12 www.huffingtonpost.com
 “Occupy Wall Street protester’s sign says 94 percent of deeper-pocketed candidates win,” Tampa Bay Times PoliticFact.com Monday, October 17th, 2011
 “We are here to serve advertisers. That is our raison d’etre.”— the C.E.O. of Westinghouse(CBS), Advertising Age, February 3, 97
 “What Makes Mainstream Media Mainstream”, Noam Chomsky, Z Magazine, October, 1997
 Title 2 Chapter 14 article 431 section (B) (i) of the US Code defines the press as exempt.
 “Samuel Alito, Supreme Court Justice, Takes On Citizens United Critics” Mark Sherman 11/17/12 Huffington Post http://www.huffingtonpost.com/2012/11/17/samuel-alito-supreme-cour_n_2150018.html
 “The Media’s Shameful, Inexcusable Distortion Of The Supreme Court’s Citizens United Decision,” Dan Abrams Feb 8th, 2012 http://www.mediaite.com/online/the-medias-shameful-inexcusable-distortion-of-the-supreme-courts-citizens-united-decision/
 “The Essential Elements of Corporate Law: What is Corporate Law?” 7/2009, Armour, Hansmann, Kraakman, Havard Law School, John M. Olin Center for Law, Economics, and Business
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 “Senator By Day, Telemarketer By Night,” Alex Blumberg March 30, 2012 NPR Planet Money
 “Call Time For Congress Shows How Fundraising Dominates Bleak Work Life,” Grim and Siddiqui, Jan 8th, 2013. Huffpost Politics
 The Reverend Martin Luther King Jr. speaking to the AFL-CIO on Dec. 11, 1961