If this is indeed the frame the court applies, it may be headed in exactly the wrong direction; there’s reason to believe that “ingratiation and access” are if anything more, not less, corrosive than quid-pro-quo corruption. Some reformers have suggested tackling that problem by adding resources to the system, rather than attempting to prohibit them, and Gerken takes a similar approach in her search for a silver lining:

Perhaps Citizens United — which may impose limits on Congress’s power to regulate that extend well beyond corporate spending — will push reform in a new direction. Rather than trying to limit the power of money in politics, we should harness money’s power to fix politics.

For example, matching rules for small donors (which convert a $20 donation into, say, $100 or $200) give politicians a reason to reach out to working-class and middle-class voters. While campaign finance has always tried to level down — restricting the ability of the monied to influence politics — the better strategy going forward may be to level up by giving everyday voters a bigger say.

Whatever happens, and however broad the ruling’s effect is, it seems likely that the amount of money in politics will continue to rise. That means a continuing role for journalists in tracking spending, monitoring influence, and making the business of politics transparent to the public.

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Greg Marx is a CJR staff writer. Follow him on Twitter @gregamarx.