Loyola of Los Angeles Law Review Volume 32 Number 1 The Sixth Annual Fritz B. Burns Lecture—Protecting Religious Liberty in the New Article 8 Millennium: Should We Amend the Religion Clauses of the United States Constitution? 11-1-1998 Beyond Bellotti Adam Winkler Follow this and additional works at: https://digitalcommons.lmu.edu/llr Part of the Law Commons Recommended Citation Adam Winkler, Beyond Bellotti, 32 Loy. L.A. L. Rev. 133 (1998). Available at: https://digitalcommons.lmu.edu/llr/vol32/iss1/8 This Article is brought to you for free and open access by the Law Reviews at Digital Commons @ Loyola Marymount University and Loyola Law School. It has been accepted for inclusion in Loyola of Los Angeles Law Review by an authorized administrator of Digital Commons@Loyola Marymount University and Loyola Law School. For more information, please contact
[email protected]. BEYOND BELLOTTI Adam Winkler* I. INTRODUCTION In the two decades since the United States Supreme Court first held unconstitutional a state ban on corporate political speech con- cerning ballot initiative measures in FirstNational Bank of Boston v. Bellotti,1 the importance of the initiative 2 process in state governance has grown remarkably. In the last decade alone, the number of state ballot measures decided by voters has more than doubled from forty- one to ninety.3 Over that same period, the Court has unsettled the le- gal landscape of corporate electoral speech doctrine. In the notable decisions in FEC v. Massachusetts Citizens for Life (MCFL)4 and Austin v. Michigan Chamber of Commerce,5 the Court has seemingly undermined the rule and reasoning of Bellotti.