which had upheld a state law that prohibited corporations from using treasury funds to support or oppose candidates in elections did not violate the First or Fourteenth Amendments. The Court also overruled the portion of McConnell that upheld such restrictions under the BCRA. In other words, the ruling was considered to hold that "political spending is a form of protected speech under the First Amendment". In McCutcheon v. Federal Election Commission (2014), the Court ruled that federal aggregate limits on how much a person can donate to candidates, political parties, and political action committees, combined respectively in a two-year period known as an "election cycle", violated the Free Speech Clause of the First Amendment. Flag desecration The divisive issue of flag desecration as a form of protest first came before the Supreme Court in Street v. New York (1969). In response to hearing an erroneous report of the murder of civil rights activist James Meredith, Sidney Street burned a 48-star U.S. flag. Street was arrested and charged with a New York state law making it a crime "publicly [to] mutilate, deface, defile, or defy, trample upon, or cast contempt upon either by words or act [any flag of the United States]". The Court, relying on Stromberg v. California (1931), found that because the provision of the New York law criminalizing "words" against the flag was unconstitutional, and the trial did not sufficiently demonstrate he had been convicted solely under the provisions not yet deemed unconstitutional, the conviction was unconstitutional. The Court, however, "resist[ed] the pulls to decide the constitutional issues involved in this case on a broader basis" and left the constitutionality of flag-burning unaddressed. The ambiguity with regard to flag-burning statutes was eliminated in Texas v. Johnson (1989). In that case, Gregory Lee Johnson burned an American flag at a demonstration during the 1984 Republican National Convention in Dallas, Texas. Charged with violating a Texas law prohibiting the vandalizing of venerated objects, Johnson was convicted, sentenced to one year in prison, and fined $2,000. The Supreme Court reversed his conviction. Justice William J. Brennan, Jr. wrote in the decision that "if there is a bedrock principle underlying the First Amendment, it is that government may not prohibit the expression of an idea simply because society finds the idea offensive or disagreeable." Congress then passed a federal law barring flag burning, but the Supreme Court struck it down as well