I'm not sure that many people draw the distinction you're trying to make. Kennedy's opinion itself describes the outcome of Citizens United in terms of campaign

I'm not sure that many people draw the distinction you're trying to make. Kennedy's opinion itself describes the outcome of Citizens United in terms of campaign finance reform: "A campaign finance system that pairs corporate independent expenditures with effective disclosure has not existed before today." https://supreme.justia.com/cases/federal/us/558/310/#tab-opinion-1963051 https://supreme.justia.com/cases/federal/us/558/310/#tab-opi... Virtually every bit of media coverage describes it in similar terms too. Still, it was a 5-4 case that produced five opinions, so if that's the hair you want to split, so be it. I think my original comment stands just as well if it's amended to "Aren't we trying that already? Citizens United already dramatically relaxed ELECTION SPENDING rules."