It is fitting that the third anniversary of Citizens United v. Federal Election Commission fell on inauguration weekend. The case allowed new ways for citizens to participate in campaigns — a fact publicly derided by progressives and reformers yet privately taken advantage of by the candidates they support, including President Obama. Despite the liberal condemnation of the money Citizens United brought to campaigns, the decision has benefited the American voter.

Citizens United allowed corporations and unions to make independent expenditures in support of or opposition to a candidate. A case decided by the U.S. Court of Appeals just weeks later, SpeechNow.org v. Federal Election Commission, held that organizations with a major purpose of making such independent expenditures must register as political action committees, but further that it infringed on the right of free speech to limit the source or size of contributions to such an independent expenditure-only PAC.