In Federal Election Comm'n v. Massachusetts Citizens for Life, Inc., 479 U.S. 238, 259-60, 107 S. Ct. 616, 93 L. Ed. 2d 539 (1986), the Court found such exhortations where a publication urged voters to vote for pro-life candidates, and identified and provided pictures of specific candidates fitting that description. The Court said that "the fact that this message is marginally less direct than 'Vote for Smith' does not change its essential nature. The publication goes beyond issue discussion to express electoral advocacy." Id. The communication in question in Massachusetts Citizens for Life, 479 U.S. 238, 93 L. Ed. 2d 539, 107 S. Ct. 616, was held to be express advocacy subject to FECA's absolute prohibition of direct expenditure of corporate funds in connection with any election. This prohibition is an exception to Buckley's rule that independent expenditures may not be limited. See infra note 11. However, the Court in Massachusetts Citizens for Life held that as applied to the nonprofit corporation involved, the provision was unconstitutional.