finance. In Federal Election Commission v. Wisconsin Right to Life, Inc., it held that certain advertisements might be constitutionally entitled to an exception from the 'electioneering communications' provisions of McCain-Feingold limiting broadcast ads that merely mention a federal candidate within 60 days of an election. On remand, a lower court then held that certain ads aired by Wisconsin Right to Life in fact merited such an exception. The Federal Election Commission appealed that decision, and in June 2007, the Supreme Court held in favor of Wisconsin Right to Life. In an opinion by Chief Justice John Roberts, the Court declined to overturn the electioneering communications limits in their entirety, but established a broad exemption for any ad that could have a reasonable interpretation as an ad about legislative issues. Also in 2006, the Supreme Court held that a Vermont law imposing mandatory limits on spending was unconstitutional, under the precedent of Buckley v. Valeo. In that case, Randall v. Sorrell, the Court also struck down Vermont's contribution limits as unconstitutionally low, the first time that the Court had ever struck down a contribution limit. In March 2009, the U.S. Supreme Court heard arguments about whether or not the law could restrict advertising of a documentary about Hillary Clinton. Citizens United v. Federal Election Commission was decided in January 2010, the Supreme Court finding that §441b's restrictions on expenditures were invalid and could not be applied to Hillary: The Movie. DISCLOSE Act of 2010 The DISCLOSE Act (S. 3628) was proposed in July 2010. The bill would have amended the Federal Election Campaign Act of 1971 to prohibit government contractors from making expenditures with respect to such elections, and establish additional disclosure requirements for election spending. The bill would have imposed new donor and contribution disclosure requirements on nearly all organizations that air political ads independently of candidates or the political parties. The legislation would have required the sponsor of the ad to appear in the ad itself. President Obama argued that the bill would reduce foreign influence over American elections. Democrats needed at least one Republican to support the measure in order to get the 60 votes to overcome GOP procedural delays, but were unsuccessful. Current proposals for reform Voting with dollars The voting with dollars plan would establish a system of modified public financing coupled with an anonymous campaign contribution process. It was originally described in detail by Yale