ABSTRACT
Congress has attempted to regulate independent expenditures for over a century, and these attempts have not been without controversy. As with many controversies in the US, the courts have been involved, and much of the debate about the balance between equality and free speech has played out in the Supreme Court. The value of free speech is about more than standing on a street corner and speaking one's mind. The Buckley Court focused on quid pro quo corruption as the key compelling interest that might justify restrictions on free speech. The Justices agreed that the government has a compelling interest in preventing corruption. They were particularly concerned with quid pro quo corruption, in which a financial contribution is exchanged knowingly for some favor or legislative preference. Moreover, of "almost equal concern as the danger of actual quid pro quo arrangements is the impact of the appearance of corruption stemming from public awareness of the opportunities for abuse".
