The U.S. Supreme Court case Federal Election Commission v. Massachusetts Citizens for Life, Inc., 1986, dealt with the question of whether a non-profit corporation could use its general treasury funds to distribute pamphlets opposing certain political candidates in violation of federal election laws. The court ruled that Massachusetts Citizens for Life (MCFL), as an ideologically-based nonprofit organization, was not subject to the same restrictions as business corporations under the Federal Election Campaign Act (FECA). This decision hinged on three characteristics unique to MCFL: it was formed for express political purposes; it had no shareholders who might have a claim on corporate earnings; and it did not accept contributions from businesses or unions. Therefore, prohibiting MCFL from using its funds in this manner would infringe upon First Amendment rights because such organizations do not pose the same risk of corruption as traditional corporations.

In the dissenting opinion for Federal Election Commission v. Massachusetts Citizens for Life, Inc., Justice Blackmun argued that the majority's decision to exempt MCFL from campaign finance restrictions was a departure from precedent and could potentially undermine future campaign finance regulation. He contended that the Court had previously upheld similar restrictions on corporations in order to prevent corruption or its appearance, and there was no reason why MCFL should be treated differently just because it is an ideological corporation. Moreover, he warned that this ruling might open a loophole allowing corporations to evade regulations by simply reorganizing themselves as ideological entities like MCFL. Furthermore, he disagreed with the majority’s view that these restrictions infringed upon First Amendment rights of free speech; rather they were necessary measures to maintain integrity in political process.