We are now in a position to grasp how the civil rights language works as a supplement to the marketplace language. Corporations share with all persons free-speech rights in the political sphere. The decision in Citizens United aims to secure these rights for a historically disenfranchised class of persons so that this class of persons may freely compete in the political marketplace and so that all may benefit from this enriched competition. Two different strands from two different eras of minority discourse are mobilized on behalf of deregulating corporate electoral speech: the classic progressive equal-rights argument and the more recent all-are-enriched-by-diversity argument. Drawing on both to advance what Justice Stevens, in his dissent, notes that the public has never clamored for more of, namely, corporate influence in politics, Justice Kennedy positions the court as enfranchising not the powerful, but the disliked, unwanted, and historically excluded. Removing the boot from the necks of this class of persons simultaneously advances the cause of universal rights and enriches the political marketplace of democracy.

Wendy Brown, Undoing the Demos, loc. 336