NRWCNational Right to Work Committee (Springfield, VA; est. 1955)
NRWCNorthern Rivers Writers' Centre
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Taking the rest of Citizens United seriously, the NRWC dicta appeared to be in serious danger.
It stated that NRWC has "little relevance here" because the case "involved contribution limits, which unlike limits on independent expenditures have been an accepted means to prevent quid pro quo corruption." (245)
The brief aside on NRWC shows the Court's apparent strategy: keep the evidentiary standard on proving corruption low and the definition of corruption loose when it comes to considering the constitutionality of contribution limitations, but keep the evidentiary standard impossibly high and the definition of corruption extremely narrow when it comes to considering the constitutionality of spending limitations.
MCFL and NRWC could be viewed as a logical extension of the Buckley command that the Court take special care to review congressional limits on expenditures.
at 155 ("In sum, our cases on campaign finance regulation represent respect for the 'legislative judgment that the special characteristics of the corporate structure require particularly careful regulation.'" (quoting NRWC, 459 U.S.
Recall that the Court in NRWC justified its law based upon the "substantial aggregations of wealth" accomplished with the corporate form that could be used to build "war chests" and incur "political debts," (49) a classic anticorruption rationale.
In a single paragraph, the joint majority opinion resolved the issue: it simply cited to Austin, Beaumont, Colorado II, and NRWC on the special need to regulate corporations and the need to prevent circumvention of valid contribution limits, and left it at that.
The Court's citation to NRWC in support of the barometer equality rationale is curious, given that NRWC did not endorse that rationale.