labeled as such. Corporations including Monsanto and DuPont spent $45 million against Prop 37 - five times more than the money spent by supporters of the proposition. The proposition was defeated by a margin of 51% to 48%, a result that left many pro-Prop 37 groups blaming unfair financing as the reason for the defeat. Still, other political scientists disagree, believing that there is no definitive evidence that links corporation donations to referendum results. For example, the campaign around California's Proposition 188, a ballot initiative aimed at lifting bans on smoking, is another example of unequal spending between corporations and others. Businesses spent over $19,000,000 in favor of Prop 188, while non-businesses spent less than $2,000,000 in opposition. Nevertheless, in this case, voters ultimately voted against Proposition 188. Similarly, the gambling industry in California has spent tens of millions of dollars since 1912 on referendums regarding gambling rules. However, only 25% of the referendums they have supported monetarily have passed. Support and criticism First National Bank of Boston v. Bellotti (1978), referred to by Linda Greenhouse as "the most important Supreme Court case no one's ever heard of," did not elicit a very strong reaction from the media and the public. Most of the discourse pertaining to the case relates to the decision's effects on the role of money in politics and corporate rights. Support Those who support the Bellotti decision saw it as a culmination of constitutional thinking on the issue of corporate political speech. These scholars and lawyers praise the ruling for treating corporate speech as equal as individual speech and thus increasing the information provided to voters during elections. According supporters, there is a long history of legislative and judicial decisions that justifies the Bellotti decision. While pre-1900 Supreme Courts believed that corporations did not deserve any protection under the First Amendment, by 1970 some lower courts were beginning to recognize First Amendment protection to "corporate speech." Lawyer Robert Prentice stated that First Amendment protection for corporations has worked its way into the decisions of the Supreme Court since the 1940s, in cases such as Valentine v. Chrestensen (1942), Pittsburgh Press Co. v. Pittsburgh Commission on Human Relations (1973) and Virginia State Pharmacy Board v. Virginia Citizens Consumer Council (1976). From 1973 to Chief Justice Burger's departure in 1986, "the Burger Court ... invalidated every commercial speech ban considered," building up precedents for the Bellotti decision. Supporters