Federal law had long prohibited corporations and unions from using general treasury funds to make either direct contributions to candidates or independent expenditures that expressly advocate the election or defeat of a candidate. It didn't matter where the ads appeared--print, online, or TV. The rationale for these restrictions was plain: Congress believed that without them, rich corporations and unions could use their deep pockets to buy ads that would drown out other speech and unfairly influence federal elections. All this seemed specifically at issue in "Citizens United v. Federal Election Commission," then, was the scope of some amendments to the Federal Election Campaign Act (FECA). The amendments were part of the Bipartisan Campaign Reform Act of 2002 (BCRA), more commonly referred to as "McCain-Feingold." These provisions added several additional campaign finance restrictions beyond the original ban on express advocacy. Under McCain-Feingold, corporations and unions were also barred from using their general treasury funds to make independent expenditures for so-called "electioneering communications." This ban was a broader prohibition than the preexisting FECA bans. Nevertheless, these new restrictions only applied in a few specified situations. The author cites the "Citizens United" case as an example. (Contains 10 notes.)