<P> Kathleen M. Sullivan, professor at Stanford Law School and Steven J. Andre, adjunct professor at Lincoln Law School, argued that two different visions of freedom of speech exist and clashed in the case . An egalitarian vision skeptical of the power of large agglomerations of wealth to skew the political process conflicted with a libertarian vision skeptical of government being placed in the role of determining what speech people should or should not hear . Wayne Batchis, Professor at the University of Delaware, in contrast, argues that the Citizens United decision represents a misguided interpretation of the non-textual freedom of association . </P> <P> The four other scholars of the seven writing in the aforementioned New York Times article were critical . Richard L. Hasen, Distinguished Professor of election law at Loyola Law School argued differently from his Slate article above, concentrating on the "inherent risk of corruption that comes when someone spends independently to try to influence the outcome of judicial elections", since judges are less publicly accountable than elected officials . Heather K. Gerken, Professor of Law at Yale Law School wrote that "The court has done real damage to the cause of reform, but that damage mostly came earlier, with decisions that made less of a splash ." Michael Waldman, director of the Brennan Center for Justice at N.Y.U. School of Law, opined that the decision "matches or exceeds Bush v. Gore in ideological or partisan overreaching by the court", explaining how "Exxon or any other firm could spend Bloomberg - level sums in any congressional district in the country against, say, any congressman who supports climate change legislation, or health care, etc ." and Fred Wertheimer, founder and president of Democracy 21 considered that "Chief Justice Roberts has abandoned the illusory public commitments he made to' judicial modesty' and' respect for precedent' to cast the deciding vote for a radical decision that profoundly undermines our democracy," and that "Congress and presidents past have recognized this danger and signed numerous laws over the years to prevent this kind of corruption of our government ." </P> <P> The New York Times stated in an editorial, "The Supreme Court has handed lobbyists a new weapon . A lobbyist can now tell any elected official: if you vote wrong, my company, labor union or interest group will spend unlimited sums explicitly advertising against your re-election ." Jonathan Alter called it the "most serious threat to American democracy in a generation". The Christian Science Monitor wrote that the Court had declared "outright that corporate expenditures cannot corrupt elected officials, that influence over lawmakers is not corruption, and that appearance of influence will not undermine public faith in our democracy". </P> <P> In 2012, Ben Cohen, the co-founder of Ben & Jerry's ice cream, founded Stamp Stampede, a sustained protest to demonstrate widespread support for a proposed constitutional amendment to overturn Citizens United . The campaign encourages people to rubber stamp messages such as "Not To Be Used for Bribing Politicians" on paper currency . In 2014, Cohen told Salon, "As long as the Supreme Court rules money is speech, corporations and the wealthy are using it by giving piles of it to politicians to pass or not pass laws that they want . Now, the rest of the people, (those) who don't have that money, can actually make their voice heard by using money to stamp a message out ." </P>

How did citizens united open the door to the creation of super pacs