14 In NCPAC, the Court reiterated that the Government may not limit the spending of non-profits. The Court invalidated a law that restricted a group’s expenditures in support of a candidate who had accepted public financing. See NCPAC, 470 U.S. at 501. The Court stated that citizens’ “collective action in pooling their resources to amplify their voices” is “entitled to full First Amendment protection . . . .” Id. at 495. In MCFL, the Court again underscored that non-profit advocacy groups are generally entitled to raise and spend unlimited money on elections. The Court invalidated an expenditure limit imposed on a non-profit corporation that had distributed a newsletter promoting pro-life candidates. The Court noted that individuals “contribute to a political organization in part because they regard such a contribution as a more effective means of advocacy than spending the money under their own personal direction.” MCFL, 479 U.S. at 261. The Court added that “[v]oluntary political associations do not suddenly present the specter of corruption merely by assuming the corporate form.” Id. at 263; see also Austin, 494 U.S. at 701 (Kennedy, J., dissenting) (MCFL held that “a nonprofit corporation engaged in political discussion of candidates and elections has the full protection of the First Amendment”). Adhering to MCFL, the McConnell Court ruled that BCRA’s ban on certain electioneering communications could not validly be applied to non-profit corporations. See McConnell, 540 U.S. at 210-11. The principles set forth in Cal-Med, Citizens Against Rent Control, NCPAC, and MCFL are rooted in the Court’s consistent holdings beginning with Buckley that individual citizens may spend money without limit (apart from the limit on their own contributions to candidates or parties) in support of the election of particular candidates. After all, if one