BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                   AJR 22|
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                                 THIRD READING


          Bill No:  AJR 22
          Author:   Wieckowski (D)
          Amended:  3/14/12 in Assembly
          Vote:     21

           
           SENATE ELECTIONS & CONST. AMEND. COMM.  :  3-2, 5/8/12
          AYES:  Correa, De Le�n, Lieu
          NOES:  La Malfa, Gaines


           SUBJECT  :    Campaign finance reform

           SOURCE  :     Public Citizen


           DIGEST  :    This resolution (1) memorializes the 
          Legislatures disagreement with the decision of the United 
          States Supreme Court in Citizens United v. Federal Election 
          Commission, and (2) calls upon the United States Congress 
          to propose and send to the states for ratification a 
          constitutional amendment to overturn Citizens United v. 
          Federal Election Commission and to restore constitutional 
          rights and fair elections to the people.

           ANALYSIS  :    This resolution is in response to the decision 
          of the U.S. Supreme Court case Citizens United v. Federal 
          Election Commission (2010) 130 S.Ct. 876 which centered 
          around the provision in the federal Bipartisan Campaign 
          Reform Act (BCRA) of 2002 (known as the "McCain-Feingold" 
          Law) which prohibited corporations and unions from using 
          general treasury funds to make "independent expenditures" 
          for "electioneering communications" within 60 days of a 
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          general election or within 30 days of a primary election.  
          In past cases the court upheld the right of Congress and 
          the states to regulate campaign financing.  In Citizens 
          United the court overturned these decisions and struck down 
          the BCRA provisions restricting corporations and unions use 
          of making independent expenditures.  Since this decision at 
          least two courts have weighed in on the issue, one which 
          appears to extend the Citizens United decision to 
          independent expenditures (SpeechNow.org v. FEC (2010) - a 
          Circuit Court of Appeal decision) and the other which seems 
          to limit it (Western Tradition Partnership v. Attorney 
          General of Montana, a Montana state Supreme Court 
          decision).

          At the time of this writing, at least 13 resolutions 
          seeking to overturn Citizens United had been introduced in 
          either the U.S. House of Representatives or the U.S. 
          Senate.  Although all seek to overturn Citizens United, 
          they do so in different ways.  Some of the resolutions 
          simply call for overturning Citizens United without stating 
          which of the Court's several holdings would be overturned.  
          (See e.g., H.J. Res. 86, introduced by Rep. Sutton; S.J. 
          Res. 29, introduced by Senators Harkin et.al.)  Some of the 
          resolutions introduced thus far proclaim, in one way or 
          another, that corporations are not "natural persons" and 
          thereby not protected by any of the rights protected by the 
          United States Constitution.  (See e.g., H.J. Res. 90, 
          introduced by Rep. Deutch; S.J. Res. 33, introduced by 
          Senator Sanders; and H.J. 88 by Rep. McGovern.)  Still 
          others would overturn Citizens United more narrowly by 
          merely affirming Congress' power to regulate campaign 
          contributions and expenditures. (See e.g., H.J. Res. 72, 
          introduced by Rep. Schrader; H.J. Res. 8, introduced by 
          Rep. Kaptur.)  State and local resolutions calling upon 
          Congress to propose and submit a constitutional amendment 
          similarly vary in terms of which aspects of Citizens United 
          should be overturned.

          Existing law, pursuant to Amendment I of the U.S. 
          Constitution as applied to the states by Amendment XIV of 
          the U.S. Constitution, provides that neither Congress nor 
          the states may enact any law respecting the establishment 
          of religion, or prohibiting the free exercise thereof; or 
          abridging the freedom of speech, or of the press; or the 

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          right of the people peaceably to assemble, and to petition 
          the Government for a redress of grievances.  

          What the basic question this resolution presents is whether 
          or not corporations should be recognized as a "person" 
          under the First Amendment of the U.S. Constitution giving 
          them the protection of free speech or not.   So far the 
          courts have held that corporate bodies are protected by the 
          First Amendment and by many other constitutional provisions 
          as well.

          According to the authors, the "U.S. Supreme Court's ruling 
          in Citizens United v. Federal Election Commission ignored 
          precedent and opened the door for unlimited corporate 
          donations advocating for and against candidates.  AJR 22 
          would put California's legislature on record in opposition 
          to this ruling and would call upon the U.S. Congress to 
          propose and send to the states for ratification a 
          constitutional amendment to overturn Citizens United and 
          restore constitutional rights and fair elections to the 
          people."  The authors contend that this resolution is part 
          of a "national grassroots movement" that believes that 
          "�c]orporations are not people and money is not speech."  
          The authors also contend that people's trust of government 
          is at an all-time low, and that decisions like Citizens 
          United only "further erode the public's faith that the 
          people's interest will come before those of wealthy special 
          interests."  Quoting Justice Stevens' dissent in Citizens 
          United, the authors contend "legislators have a compelling 
          constitutional basis, if not also a democratic duty, to 
          take measures designed to guard against the potentially 
          deleterious effects of corporate spending in local and 
          national elections."  The authors believe that this 
          resolution will "send a message that we want Congress to 
          perform that democratic duty."

           NOTE:  See the Assembly Judiciary Committee and Senate 
                 Elections and Constitutional Amendments Committee 
                 analysis for a comprehensive discussion of the issue 
                 presented by the resolution.

           FISCAL EFFECT  :    Fiscal Com.:  No

           SUPPORT  :   (Verified  5/9/12)

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          Public Citizen (source)
          Berkeley City Council
          California Church Impact
          California Faculty Association
          California Labor Federation 
          California League of Conservation Voters
          California Nurses Association
          California Professional Firefighters
          California Teachers Association
          City of Santa Monica
          Common Cause
          Consumer Watchdog
          CREDO Action
          Davis City Council
          International Forum on Globalization 
          Laborers Local 777 and 792


          DLW:kc  5/9/12   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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