The Indicator from Planet Money
The Indicator from Planet Money

Oct 29, 2026 · 9 min

Montana tests a new way to challenge corporate campaign spending

Can Montana end Citizens United?

I-194 could test whether a state can restrict corporate political spending after Citizens United, even if courts ultimately reject it.

3 key takeaways
  1. 1Montana’s history of resisting wealthy political influence shapes its latest campaign-finance initiative.
  2. 2I-194 would use corporate law to limit political spending by companies and other artificial entities.
  3. 3Even a court defeat could turn the initiative into a national protest against Citizens United’s legacy.

Don't miss

Jeff Mangan explains why he is pursuing I-194 despite expecting a major constitutional challenge and possible defeat in court.

The brief

Montana’s fight with political money reaches back to William A. Clark’s 1899 attempt to buy a U.S. Senate seat, a scandal that helped inspire the 17th Amendment.

I-194 would prohibit corporations and other artificial entities from contributing to political campaigns by changing Montana’s corporate law, rather than directly rewriting federal election rules.

Jeff Mangan describes how Citizens United drove up campaign costs and outside spending in Montana, then explains the state-level strategy he developed with Tom Moore.

The initiative has bipartisan support but faces opposition from Republicans and business groups, with organizers expecting a First Amendment lawsuit modeled partly on a Hawaii challenge.

Legal experts doubt I-194 would survive constitutional review, yet supporters argue that passing it could create national pressure to confront money in elections.

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