Taken together, corporations now enjoy greater First Amendment political speech capabilities than individuals - a stunning outcome - because they may spend unlimited funds on independent expenditures and contribute to their PACs administrative fund to essentially subsidize the SSFs ability to raise and expend candidate contributions.  At the same time, individuals who band together to engage in political speech are burdened by an unnecessary requirement that they form two distinct entities in order to perform two legally permissible acts - contributing to candidates (subject to contribution limits), and independently advocating for or against candidates if they wish to exercise their right to make unlimited contributions for this latter activity.  Finally, it is nonsensical, and an infringement upon the very First Amendment rights of association and speech underlying SpeechNOW, that one (even a corporation) who may lawfully spend unlimited sums for independent expenditures cannot also do so in conjunction with others of like mind who share that political view.

Based on this analysis, there are three core issues to address.  First, providing individuals with at least the same free speech rights as that enjoyed by corporations.  Second, ensuring the exercise of free speech may be done in concert with others when it may lawfully be done by ones' self.  Third, eliminating the infringement upon the first amendment by requiring that independent expenditures lawfully funded by unlimited contributions and direct contributions funded by limited contributions be made by separate PACs, even though subject to identical registration and reporting requirements. 

Citizens United and SpeechNOW form the basis upon which a new approach to PACs should be built to address these issues.  First, PACs should be free to accept both unlimited contributions for independent expenditures AND limited contributions for direct candidate contributions.  So long as contributors indicate their purpose and the contributed funds are segregated within the PAC, there is no rationale for forcing one who engages in political speech to do so through two separate vehicles, particularly when corporations are not similarly burdened.  While there will be questions as to allocation between accounts of the administrative expenses of a joint-purpose PAC, logistic considerations are not sufficient to deny first amendment rights.  Secondly, PACs should be free to accept unlimited corporate contributions to their independent expenditure-only accounts.  Corporations can now make independent expenditures freely, and independent expenditure-only PACs may accept unlimited contributions, all of which is disclosed to the FEC.  There is no rationale to prevent speakers from speaking together in the exact same way they may do so separately, particularly where there is no element of quid pro quo corruption.  These changes in the regulations governing PACs are consistent with the rulings of Citizens United and SpeechNOW, embrace the underlying principle of protecting First Amendment guarantees of free speech in politics, and ensure individuals have at least the same level of political speech rights as corporations now enjoy.

Active supporters of a PAC may make more than a single contribution across multiple reporting periods.