majority as based on two propositions. The first was that the Court has recognized that "First Amendment protections extend to corporations," for which the Court cited Bellotti as an example. The Court "returned to the principle established in Buckley and Bellotti that the Government may not suppress political speech based on the speaker's corporate identity." The Court cited Bellotti in arguing that political speech is "indispensable to decision making in a democracy and [that] this is no less true because the speech comes from a corporation." The second proposition addressed contribution expenditure and corruption. The Court ruled that independent expenditure limits were unconstitutional because, unlike campaign contribution limits, they fail to "serve any substantial government interest in stemming the reality or appearance of corruption in the electoral process." The Court argued, "Austin upheld a corporate independent expenditure restriction" by recognizing a "new governmental interest" in preventing corruption to "bypass Buckley and Bellotti." The Court rejected the anti-distortion reasoning argued in Austin and returned to the quid pro quo conception of corruption used in Buckley, stating that "independent expenditures, including those made by corporations, do not give rise to corruption or the appearance of corruption." In overruling Austin, the Citizens majority insisted, "before Austin, the court had not allowed the exclusion of a class of speakers from general public dialogue." The Court did concede that the Bellotti case "did not address the constitutionality" of bans on "corporate independent expenditures to support candidates." However, the court reasoned that such bans "would have been unconstitutional under Bellotti's central principle that the First Amendment does not allow political speech restrictions based on a speaker's corporate identity." Effects on policy Effects on legislation While the First National Bank of Boston v. Bellotti ruling set a precedent for allowing corporate spending in elections, it did not directly lead to federal campaign law changes because of its narrow focus. The Bellotti decision focused on state referendums, not the election of candidates. In April 1978, when the Supreme Court decided First National Bank of Boston v. Bellotti, 31 states had laws regulating corporate spending on ballot initiatives. However, not all of these state laws were annulled by the Supreme Court ruling. Universal caps on donations for ballot initiatives as well as specific bans aimed to prevent "undue" corporate influence on referendums were still considered constitutional. Of these 31 states, 18 of them, including Massachusetts, had laws that would