Rick Hasen has an interesting column at Slate, discussing efforts to chip away at campaign finance regulations. Hasen suggests it will only get worse. "Opponents of reasonable regulation have a new target: trying to keep the flow of campaign money secret." For example, Citizens United submitted an advisory opinion request to the Federal Election Commission (FEC), asking if it qualifies for the "media exemption" under the Federal Campaign Finance Act.

Americans United for Separation of Church and State asked the Internal Revenue Service (IRS) to investigate a Florida church for improper electioneering. Americans United filed the complaint against Dove World Outreach Center in Gainesville, Florida, as a result of the church posting a sign on its property that read, "No Homo Mayor," in an apparent attempt to deter people from voting for Craig Lowe, an openly gay Gainesville mayoral candidate.

Reps. John Tanner (D-TN) and Michael Castle (R-DE) have introduced HR 4918, the Redistricting Transparency Act of 2010. The bill would require states to put together redistricting plans for U.S. House district boundaries in a public process. This includes having an Internet site to inform the public of the planning. The site would have to provide advance notice of any meetings on the subject of redrawing the boundaries of the districts.

The Senate Judiciary committee held a hearing tilted, "We the People? Corporate Spending in American Elections after Citizens United." During the hearing opponents of the ruling argued that the case exemplified that the Roberts Court has abandoned judicial restraint. Conversely, witness Bradley Smith, described the responses to the Citizens United decision as "hysteria." Smith also caused hysteria during the hearing when he referenced Vermont legislators as "freaking out" about the decision.