be considered unconstitutional after the Bellotti decision. In the aftermath of Bellotti, several states changed their laws relating to spending on referendums. In 1981, Iowa's state legislature updated their campaign finance laws to state, It is unlawful for any insurance company, savings and loan association, bank, and or corporation ... to contribute any money, property, labor, or thing of value, directly or indirectly, to any committee, or for the purpose of influencing the vote of any elector, except that such resources may be so expended in connection with a ballot issue, however all such expenditures are subject to the disclosure requirements of this chapter. Montana had previously banned all corporate donations for or against ballot issues. In October 1978, this law was overturned by the Court of Appeals for the Ninth Circuit citing First National Bank of Boston v. Bellotti. On December 23, 1986, the General Court of Massachusetts approved a series of changes to its campaign finance laws, and only then officially changed the law governing corporate spending on ballot initiatives. In "An Act Further Regulating Political Campaign Financing," the General Court stated that they were "striking out" Chapter 55, Section 8, the law annulled by the Bellotti decision. Furthermore, a new §8 law was written that in part stated, No person or persons, no political committee, and no person acting under the authority of a political committee, or in its behalf, other than a political committee organized on behalf of a ballot question campaign ... shall solicit or receive from such corporation or such holders of stock any gift, payment, expenditure, contribution or promise to give, pay, expend or contribute for any such purpose. Effects on referendums Scholars are split on whether the First National Bank of Boston v. Bellotti decision has had an overall effect on the ballot initiative process. Some scholars believe that without any regulations on corporate spending on ballot initiatives, corporations have the potential to donate much more to these campaigns than individuals or citizen groups. Some scholars maintain that this advantage gives corporations undue influence over referendum campaigns and policy outcomes. One such way corporations can use money to sway voters is through advertising and spreading information about propositions. For example, a California ballot initiative, Proposition 37 from 2012, attracted a disproportionately high level of spending from corporations. The proposition would mandate that all foods containing genetically modified organisms would have to be