Austin v. Mich. Chamber of Commerce
In Austin v. Mich. Chamber of Commerce, 494 U.S. 652 (1990), the Court held that the "danger of real or apparent corruption," when combined with "the unique state-conferred corporate structure that facilitates the amassing of large treasuries" warranted the limit on independent expenditures. Id. at 659-60.
Having found a compelling interest, the Austin Court then determined that the complete ban was narrowly tailored because it allowed corporations to make independent expenditures through separate segregated funds. Id. at 660-61.
In doing so, it noted that the rationale applied to "corporations and labor unions without great financial resources, as well as those more fortunately situated" based on "Congress' judgment that it is the potential for such influence that demands regulation." Id. at 661.