lose First Amendment protection "merely because the speaker is a corporation." However, the Austin majority held that the Michigan Chamber of Commerce, a non-profit corporation that wanted to publish a newspaper advertisement supporting a candidate, did not qualify for the non-profit exemption established in Federal Election Commission v. Massachusetts Citizens for Life, Inc (1986). The dissent in the Austin case cited the statement in Bellotti that "the legislature is constitutionally disqualified from dictating the subjects about which persons may speak and the speakers who may address a public issue." The dissent found that Massachusetts's law discriminated on the basis of the speaker's identity, and argued that the precedents of the Supreme Court, such as Bellotti, condemn this type of censorship. Scholars agree that the Austin decision was inconsistent with precedent in that the Court had previously never upheld a statue that regulated corporate independent expenditure because of a state interest in preventing corruption. McConnell v. Federal Election Commission In 2002, the Supreme Court in McConnell v. Federal Election Commission upheld the two major provisions of the Bipartisan Campaign Reform Act, which were the bans on unrestricted "soft money" donations to political parties and on electioneering communications, which are defined as any broadcast that refers to a federal candidate and is aired within a designated time frame of that candidate's election. The McConnell majority moved away from the Bellotti decision by allowing such restrictions on corporate donations. The majority accepted legislative judgment that corporate treasuries represent a threat of corruption when deployed directly in candidate elections." The McConnell dissent characterized the Austin argument concerning the "corrosive and distorting effects" of corporations as the notion that corporations "will be able to convince voters on the correctness of their ideas." The dissent argued that using this reasoning, simply "winning the marketplace of ideas" could be considered evidence of corruption. They argued that this conclusion opposed the First amendment, citing the statement from Bellotti that "the fact that advocacy may persuade the electorate is hardly a reason to suppress it." Citizens United v. Federal Election Commission In 2010, the Supreme Court in Citizens United v. Federal Election Commission overturned Austin v. Michigan Chamber of Commerce (1990), portions of McConnell v. Federal Election Commission (2003), and Section 203 of the Bipartisan Campaign Reform Act (2002) that prohibited electioneering communications by corporations. The Harvard Journal of Law and Public Policy described the reasoning of the Citizens