Spark to Flame. End Citizens United
Series Page · USA Protect Your Vote Inspired by: — Substack ROBERT REICH “How to Get Rid of “Citizens United” November 24, 2025Artist acknowledgment
This Civic Page acknowledges the reporting and creative work of Robert Reich at Substack. His work documents the enduring damage of Citizens United, exposing how corporate political spending and dark money have drowned out democratic voices, and showing that states themselves hold the power to reclaim control.“We can do away with it without a new Supreme Court. Nor do we need a constitutional amendment. There’s a far simpler way.” — Robert ReichBy crediting Robert Reich, we honor the civic courage and clarity of his work. His words anchor this page’s motifs in lived reality, ensuring that democratic voices are not drowned out by corporate capture of democracy.
Source summary paragraph
Robert Reich’s November 24, 2025 Substack article How to Get Rid of “Citizens United” lays out a clear path for dismantling the Supreme Court ruling that unleashed corporate money into American politics. He explains that reform does not require a new Court or constitutional amendment, but can be achieved through state‑level action that reasserts democratic control. This source grounds the Indictment Quadrant of the Spark to Flame grid, exposing how false power was granted to corporations and clarifying the strategy for reclaiming the fire of democracy. Read the original article here:Source attribution standard
Names are published as they appear in the original title or byline. Inconsistent usage (e.g., middle initials) is noted in the archive but not replicated unless formally presented. Platform: Substack Author: Robert Reich Article: How to Get Rid of “Citizens United” Date: November 24, 2025
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How to Get Rid of “Citizens United” We can do away with it without a new Supreme Court. Nor do we need a constitutional amendment. There’s a far simpler way. Friends, Several of you responded to my “Sunday thought” yesterday by saying that the first step out of the mess we’re in is to get rid of the Supreme Court’s bonkers Citizens United v. Federal Election Commission decision of 2010, which held that corporations are people — entitled to the same First Amendment protection as the rest of us. Corporate political spending was growing before Citizens United, but the decision opened the floodgates to the unlimited super PAC spending and undisclosed dark money we suffer from today. Between 2008 and 2024, reported “independent” expenditures by outside groups exploded by more than 28-fold — from $144 million to $4.21 billion. Unreported money also skyrocketed, with dark money groups spending millions influencing the 2024 election. Most people I talk with assume that the only way to stop corporate and dark money in American politics is either to wait for the Supreme Court to undo Citizens United (we could wait a very long time) or amend the U.S. Constitution (this is extraordinarily difficult). But there’s another way! I want to tell you about it because there’s a good chance it will work. It will be on the ballot next November in Montana. Maybe you can get it on the ballot in your state, too. Here’s the thing: Individual states — either through their legislators or their citizens wielding ballot initiatives — have the authority to limit corporate political activity and dark money spending, because they determine what powers corporations have. In American law, corporations are creatures of state laws. For more than two centuries, the power to define their form, limits, and privilege has belonged only to the states. In fact, corporations have no powers at all until a state government grants them some. In the 1819 Supreme Court case Trustees of Dartmouth College v. Woodward, Chief Justice John Marshall established that: “A corporation is an artificial being, invisible, intangible, and existing only in contemplation of law. Being the mere creature of law, it possesses only those properties which the charter of its creation confers upon it, either expressly, or as incidental to its very existence….The objects for which a corporation is created are universally such as the government wishes to promote. They are deemed beneficial to the country; and this benefit constitutes the consideration, and, in most cases, the sole consideration of the grant.” States don’t have to grant corporations the power to spend in politics. In fact, they could decide not to give corporations that power. This isn’t about corporate rights, as the Supreme Court determined in Citizens United. It’s about corporate powers. When a state exercises its authority to define corporations as entities without the power to spend in politics, it will no longer be relevant whether corporations have a right to spend in politics — because without the power to do so, the right to do so has no meaning. Delaware’s corporation code already declines to grant private foundations the power to spend in elections. Importantly, a state that no longer grants its corporations the power to spend in elections also denies that power to corporations chartered in the other 49 states, if they wish to do business in that state. All a state would need to do is enact a law with a provision something like this: “Every corporation operating under the laws of this state has all the corporate powers it held previously, except that nothing in this statute grants or recognizes any power to engage in election activity or ballot-issue activity.” Sound farfetched? Not at all. In Montana, local organizers have drafted and submitted a constitutional initiative for voters to consider in 2026 — the first step in a movement built to spread nationwide. It would decline to grant to all corporations the power to spend in elections. Called the Transparent Election Initiative, it wouldn’t overturn Citizens United — it would negate the consequences of Citizens United. (Click on the link and you’ll get the details.) The argument is laid out in a paper that the Center for American Progress published several weeks ago. (Kudos to CAP and the paper’s author, Tom Moore, a senior fellow at CAP who previously served as counsel and chief of staff to a longtime member of the Federal Election Commission.) Note to governors and state legislators: The Citizens United decision is enormously unpopular. Some 75 percent of Americans disapprove of it. But most of your governors and state legislators haven’t realized that you have the authority to make Citizens United irrelevant. My recommendation to you: Use that authority to rid the nation of Citizens United. Hopefully, Montanans will lead the way. ROBERT REICH November 24, 2025Pull Quote:
“Individual states — either through their legislators or their citizens wielding ballot initiatives — have the authority to limit corporate political activity and dark money spending, because they determine what powers corporations have.” — Robert Reich, Substack, November 24, 2025
Image Grid:
ALT Text Descriptions:
Hero Image – People Power Burns Dark Money Magnifying glass focusing sunlight into a small flame on kindling, cracked concrete backdrop. • Accessibility Text: Hero image symbolizing collective ignition of citizen action against dark money.
Clarity Quadrant – The Spark Was Always Ours Single match held between two fingers, glowing faintly against blurred crowd backdrop.
Shield Divider – No Text Dark parchment shield overlaying city skyline, protesters in foreground.
Grief Quadrant – We Watched the Fire Get Stolen Bonfire drowned by corporate silhouettes pouring dark liquid, ballots half‑buried in ash.
Indictment Quadrant – The Flame Was Never Theirs to Wield Torch labeled “Democracy” held by corporate hand, puppet strings attached to legislators, courtroom backdrop.
Reckoning Quadrant – We Reclaim the Fire, State by State Map of U.S. with ballot‑shaped flames igniting in Montana, California, and other states, sunrise breaking through smoke.
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Captions:
Hero Image Spark to Flame — Change begins with us.
Clarity Quadrant Change begins with us — clarity before ignition.
Shield Divider Divider motif — shield of civic strength.
Grief Quadrant Grief of civic passion stolen by dark money.
Indictment Quadrant Indictment of false power granted by Citizens United.
Reckoning Quadrant State‑level reckoning — reclaiming democracy’s fire.
The Fire Was Stolen. We Name Who Took It. The motifs on this page remind us that democracy’s flame was never meant to be wielded by corporations. Citizens United opened the floodgates to dark money, drowning out the voices of citizens. Yet the spark remains ours — clarity before ignition, grief for what was stolen, indictment of false power, and reckoning through state‑level action. This reflection anchors the imagery in lived reality: the magnifying glass focusing sunlight, the match glowing in the crowd, the shield divider, and the map igniting state by state. Each motif is a reminder that civic courage is not abstract — it is the fire we reclaim together.
Call to Action:
Reclaim the Fire — State by State
The path to ending Citizens United does not run through waiting for a new Supreme Court or a constitutional amendment. It runs through us — citizens and states willing to act. Legislators and ballot initiatives can strip corporations of the false power to spend in politics, restoring democracy to the people. This Civic Page calls on readers to demand state‑level action: • Organize locally to push ballot initiatives that curb corporate political spending. • Pressure legislators to redefine corporate powers and close the dark money floodgates. • Amplify voices that expose corporate capture and insist democracy belongs to citizens, not corporations. The flame was stolen, but the spark remains ours. By naming who took it and reclaiming the fire, we ensure that democracy burns bright again — fueled not by money, but by people power.
You can’t start a fire without a spark. And today, friends, we are the spark. We are the magnifying glass that turns sunlight into flame — a flame strong enough to burn away the dark money choking our democracy.

ALT Text Descriptions:
Civic Identity
Coral and red block featuring shield emblem adapted from Janiece’s website logo, with green checkmark symbolizing the word “Vote.” Text includes “Spark to Flame. End Citizens United.” and “Making Waves. Naming Names. Defending Democracy.” • Accessibility Text: Civic identity quadrant anchoring the campaign’s title, shield emblem, and affirmation of democratic defense.
Motif in Focus
Mustard yellow and beige block with centered text: “Motif in Focus: The Flame Was Never Theirs to Wield.” • Accessibility Text: Motif quadrant highlighting the central indictment theme of the Civic Page.
Source Acknowledgment
Dark gray and light gray block with campaign‑authored rally cry quote: “You can’t start a fire without a spark. And today, friends, we are the spark. We are the magnifying glass that turns sunlight into flame — a flame strong enough to burn away the dark money choking our democracy.” • Accessibility Text: Source quadrant featuring authored rally cry attribution. — Rally Cry Draft “Spark to Flame,” authored by Janiece (December 2025)
Legacy Protocol Reminder
Navy blue and coral block with red heart icon and text: “Legacy Protocol: This is a legacy record. We name the demand.” • Accessibility Text: Legacy quadrant affirming the page’s archival status and civic demand naming.
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Captions:
Civic Identity Civic Identity — shield emblem adapted from Janiece’s logo. The green checkmark represents the word “Vote.”
Motif in Focus Motif in focus — the flame was never theirs to wield
Source Acknowledgment Campaign quote — rally cry opening line anchoring the motif of spark to flame. — Rally Cry Draft “Spark to Flame,” authored by Janiece (December 2025)
Legacy Protocol Legacy protocol — this is a legacy record. We name the demand.





