If You Don’t Want To Be Chilled Stay Out Of The Freezer

Burt Likko

Pseudonymous Portlander. Homebrewer. Atheist. Recovering Republican. Recovering Catholic. Recovering divorcé. Editor-in-Chief Emeritus of Ordinary Times. Relapsed Lawyer, admitted to practice law (under his real name) in California and Oregon. On Twitter, to his frequent regret, at @burtlikko. House Likko's Words: Scite Verum. Colite Iusticia. Vivere Con Gaudium.

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83 Responses

  1. Tod Kelly says:

    Boy, am I inviting a s**tstorm for what I’m about to say, but I have a hard time not seeing this as people wanting to be able to pursue bigoted public policy, but not have to deal with being identified as a bigot.Report

    • Burt Likko in reply to Tod Kelly says:

      Then put the shoe on the other foot. Let’s say I support SSM (I do) and give my money to a “repeal prop 8” initiative. Then some local church decided to publicize that fact to its parishioners. Who include my top ten clients, who then take their legal business to another firm cross town. I’m kind of stuck, aren’t I?Report

      • Tod Kelly in reply to Burt Likko says:

        Yeah, that is a helpful exercise; it does put it the issues into better focus for me.

        Still, I’m think that given the choice of “Bad Potential Personal Consequences for Enacting Public Policy” and “Enacting Public Policy Decisions That Effect Others & Not Being Held Accountable,” I’m not so sure that I don’t want to err with the former.Report

      • DarrenG in reply to Burt Likko says:

        My instinct in that case would be not to shield you from the consequences of your actions becoming known, but I think this case could also be addressed by putting a reasonable minimum on the amount of donations that must be disclosed.

        If you’re putting $10 or $100 into a political campaign I wouldn’t much care if you were able to keep that secret. If you’re dropping $1 million into something, though, I think you should be willing to fess up and face public scrutiny.Report

      • Will Truman in reply to Burt Likko says:

        I can come up with a slightly more tangible hypothetical. When I was living in Mormonland, the my employer’s CEO fired the legal counsel upon discovering that he was gay. Now, I don’t *think* that signing a SSM petition would have gotten me fired, but I wouldn’t have bet my job on it. And there is no way that I would have signed a petition to change the law making it illegal to fire someone on the basis of sexuality, because I am pretty sure that would have gotten me fired if he ever found out about it.Report

      • DensityDuck in reply to Burt Likko says:

        Or–to pick up a hypothetical I suggested elsewhere–let’s talk about union votes and card-check. Let’s say a shop votes to go union. Is it a good thing or a bad thing to publish each worker’s name and whether they voted “yes” or “no”? Do you think that doing this would engender harmony in the workforce?Report

    • DarrenG in reply to Tod Kelly says:

      Some of it, perhaps, although here in California the entities fighting disclosure the hardest were two large institutions (the Roman Catholic and LDS churches) that didn’t want their own members to know how much institution resources were being put into a particular political initiative.Report

      • Tod Kelly in reply to DarrenG says:

        No, Burt’s “shoe on the other foot” made me walk back from that.Report

      • Patrick Cahalan in reply to DarrenG says:

        That’s largely an internal problem.

        If people want to give money to the LDS or the Mormon Church, neither has an explicit fiduciary duty to the donator to spend it any particular way.

        (this is my break with the whole corporate funding of politics: the corporation has a fiduciary duty to its stockholders, and as such political donations should show up in the financial statements).Report

        • DarrenG in reply to Patrick Cahalan says:

          I suspect many church members would disagree about the fiduciary duty part, but that’s also overly reductionist.

          Shouldn’t churches have a duty to their adherents to disclose large-scale actions taken by church leadership intended to foster a specific social or moral goal?Report

          • Patrick Cahalan in reply to DarrenG says:

            Shouldn’t churches have a duty to their adherents to disclose large-scale actions taken by church leadership intended to foster a specific social or moral goal?

            I think so.  A moral and ethical duty, certainly.

            Show me a church that follows such a policy and I might show up for a change.

            A legal duty, well, that part gets tricky…Report

          • DensityDuck in reply to DarrenG says:

            “Shouldn’t churches have a duty to their adherents to disclose large-scale actions taken by church leadership intended to foster a specific social or moral goal?”

            Yes, just like any organization. And, like any voluntary organization, the constituents can leave if they don’t like what the organization is doing.

            Unless it’s a union, of course, which can donate members’ dues to Democratic political candidates who then pass legislation making it illegal to not be part of a union.Report

  2. North says:

    Yeah I remember Rod Dreher and Maggie Gallagher were kicking up their huge fuss about the violence, intimidation and cruelty that SSM opponents were going to face because of their votes. Nothing but crickets from Rod now, Maggie of course always has something to say but not on that subject.Report

    • DensityDuck in reply to North says:

      Publishing the phone numbers and home addresses of doctors who work at abortion clinics: “This is targeting people for harassment and retributive violence!”

      Publishing the phone numbers and home addresses of people who donated to campaigns we don’t like: “If you don’t want to face the consequenes of supporting these causes then maybe you shouldn’t support them!”Report

      • North in reply to DensityDuck says:

        And how, pray tell, are doctors at abortion clinics electing to involve themselves in electoral politics?

        Publishing the phone numbers and home addresses of doctors just doing their chosen job is pretty different than making available the info that people volonteer when they involve themselves in politics.Report

        • DarrenG in reply to North says:


          And that’s without even discarding the bogus framing of “abortion clinic” or pointing out the obvious fact that there is an actual, extensive history of violence against doctors that clearly meets the “chilling effect” criteria laid out in Burt’s post.Report

        • DensityDuck in reply to North says:

          “Publishing the phone numbers and home addresses of doctors just doing their chosen job is pretty different than making available the info that people volonteer when they involve themselves in politics.”

          You’re right, it’s much more important that we punish people for their politics than for their actions.Report

          • North in reply to DensityDuck says:

            So are you saying that you don’t see the difference between a person doing their job (any job) and having their personal information presumably stolen and made public and a person submitting their personal information into the public record in order to advance a political cause and that information being public? Honestly? You honestly see no difference?


            • Gorigas in reply to North says:

              I think it’s more accurate to say that while the differences are real and make the publication of the private information of abortion doctors public worse than this case, some of the considerations apply to both situations.  The shared factors are enough to merit condemnation of the actions on that basis alone.Report

              • North in reply to Gorigas says:

                I fail to see the similarity at all beyond the fact that both are the same pieces of information.

                -Doctors info: Presumably stolen or collected under false pretenses. Private information on the individual. Disclosed without permission. Used in the past for acts of violence including violence leading to loss of life.

                -Petition signers info: Submitted volontarily under clear pretenses. Private information on the individual. Disclosed implicitly by the owner of the information when signing the petition (the act of signing the petition is implicit permission for this information to be made public record for verification purposes), so far no violence has occured at all as a consequence of the information being made public despite great hue and cry that it would be.

                Perhaps you could elaborate or point our what Im’ missing?Report

              • Will Truman in reply to North says:

                Presumably stolen or collected under false pretenses. Private information on the individual. Disclosed without permission.

                This doesn’t affect your point much one way or the other, but it’s *incredibly* difficult for doctors to keep their information private. We’ve tried, and failed, almost everywhere we have gone. So I think that there is some legal mechanism by which the information can be obtained (perhaps public records involving licensure).Report

              • North in reply to Will Truman says:

                Perhaps Will, you’d know better than I, but even so I’d say that its use is being perverted when it’s acquired and used as a form of protest.Report

              • Lyle in reply to Will Truman says:

                How far does one go to limit things. For example if you own your house and I know which county you live in I can probably get your home address from real property records. (which are online most places now).  One can find out the physicians name and education from the license board. The data base does not give practice addresses however. Of course most physicians are listed in the Yellow pages, with their phone number.Report

          • Kimmi in reply to DensityDuck says:

            Can I have you on record as supporting the publishing of law enforcement’s home addresses (on an indescriminant basis)? Or is that a different story?Report

  3. DensityDuck says:

    I think the League has had this conversation before. It was asserted that indidivuals acting in their own capacity should always be permitted anonymity in their donations, but that Big Organizations like corporations or the Catholic Church should never be permitted anonymity because of the sheer size of their donations. “What about extremely rich individuals?” Well, okay, maybe there’s some dollar limit. “What justifies setting the limit at that particular value?” Bellyfeel. “What about individuals making donations below that dollar limit but at the behest of a larger organization–like, say that the Catholic Church urges its members to donate to anti-gay-marriage campaigns?” um um umReport

  4. greginak says:

    One would imagine that opponents of SSM in Cali. who fear the chilling effect of having their donations or votes known would now have a much, much greater awareness and sensitivity to the shame, fear and hurt young gay people go through. Why i would think opponents of SSM would likely understand how gay slurs or bullying or  people saying gay folk are heading to hell in a hand basket or even gay marriage will do nothing less then destroy marriage for everybody else and put the US on GOD’s do not call list is a bit hurtful.Report

    • DensityDuck in reply to greginak says:

      Wait, I thought that we weren’t supposed to punish people for their political views and that it never happened anyway. You seem to be saying exactly the opposite. Can someone clear this up?Report

  5. wardsmith says:

    Burt, thanks for the OP and the sage way you put things. Unfortunately the case law is too emotionally charged for some to recognize the alternate considerations you and Will alluded to above. Getting your name in the paper in “the day” was one thing, but having it on the Internet 24×7 searchable by myriad search engines doesn’t help matters any. What I suspect Greg and others have missed here is that this same ruling can come around to bite /their/ interests right in the ass.

    Given what is happening to Cain, I’m suspecting that we’re going to find ourselves in a not-so-future society where /all/ politicians are going to look like Manchurian Candidates (and likely are). We’ll end up with a motley crew of professional cardboard political candidates with no apparent pasts. Probably the “democracy” we deserve, but not the ideal one IMHO. Meantime our ability to associate against “the machine” will diminish bit by bit. Or maybe I’m just a pessimist.Report

    • Patrick Cahalan in reply to wardsmith says:

      Maybe people will start to care less about this stuff.

      Generational thing.  You know those young people and their changing ideas of normal.Report

      • DarrenG in reply to Patrick Cahalan says:

        Contra Ward, I don’t think people in general much care about this stuff now.

        We still have David Vitter. Larry Craig and Mark Sanford managed to retire on their own schedules, and John Ensign was riding out his scandal just fine until it turned into a criminal investigation.

        Conventional wisdom may eventually crystallize around the idea that Cain was brought down by a sex scandal, but the reality of it is that he was never going to be the nominee before the scandal broke.Report

      • mark boggs in reply to Patrick Cahalan says:

        Don’t give me the vapors, Pat.  This *is* the important stuff.  The minute they actually start to talk about stuff that matters, most of us glaze over and look for the remote.  The minute we drift away from dicks and diapers, interns and incest, you can have my season tickets.Report

    • North in reply to wardsmith says:

      For me mMore information is better as a general rule Ward. Politics is a slow reacting field, I have no doubt people will start not giving a damn about the trivial crap as the generations roll on.Report

      • wardsmith in reply to North says:

        There was virtually nothing available about Obama prior to his election. We had a few years in the Illinois Senate, a couple of books and about 20 years missing from the resume. But if you’re fine with that, you’re bound to see much more of it. I guess I won’t even get into the tens of thousands of questionable donations all totaling less than $200 that he received from folks like ASDFJKL; We’ll see more of that too no doubt.Report

  6. Gorigas says:

    This is a pretty good post, but I’m concerned that you’re glossing the difficulties inherent in the private-public distinction in light of modern communication services.  By way of example, one of my online friends from a community where people post pseudonymously recently got a mention in a public newspaper under his real name. There were enough details to identify him to those of us who had been chatting with him for awhile, though not for the average surfer of the forum.  The article mentioned a feat that he had posted about pseudonymously before, so it’s possible that someone would make the connection, but it would require some legwork.  One of his online friends posted the article and congratulated him under his pseudonym, pointing out the feat that the article mentioned.


    This is not a violation of privacy per se, as nothing new had been made available to the public.  Nevertheless, his friend’s post changed the odds of his pseudonym being connected to his real identity from minuscule to incredibly likely.  One can distinguish this case from the above in that the original posts were done under a presumption of anonymity while the campaign donations perhaps were not, and I think that’s fair, but I think that obscures a larger point.  The real thing I’m trying to get across is that broader publication or easier access to a fact that is nevertheless “publicly available” to a sufficiently motivated person might itself constitute a violation of privacy.  At least, if not in the legally relevant sense, in a moral or normative sense.  In light of search technology, I think modern analyses of privacy should be more concerned with probabilities of a certain fact becoming widely known rather than hew to an outdated strict distinction between unambiguously private and unambiguously public information.


    In this case, I think it’s clear that such an organization intends to chill speech.  The only possible reason to publish such lists is to abet harassment, even harassment of a legal kind.  It is important to note, as Likko does, that such harassment is not actually occurring, and it is good that it is not.  Still, I think simply dismissing it on those grounds misses the important question here.  How would we react if the website was working as its creators intended it to?

    I have a dog in this fight; I’d love to be able to marry who I choose and I have a very personal stake in a world without homophobia.  Nevertheless, our response to these issues shouldn’t be determined by whether we agree with the opinions being expressed.  At minimum, I think those who are creating the site ought to be discouraged by those of us who recognize that social coercion ought to be exercised with care, as all those who support gay rights must.  As I see it, the primary triumph of the gay rights movement has been to allow more and more of the population to participate fully in the polity and society by rolling back both the reasons for and means of social coercion.  It would be a tragedy if we abandoned those principles the moment they become inconvenient.  Anyone who agrees with me that a principle triumph of the gay rights movement has been to limit the means of a collective to enforce conformity has a significant interest in creating a norm of privacy.Report

    • North in reply to Gorigas says:

      Im sympathetic to the sentiment Gorigas but I just feel the facts involved in the petition itself are being glossed over. The act of signing a petition to launch a refferenda is equivalent to standing up in the town hall and requesting the same. There is no expectation of privacy on any level, the self announcement, the self identification is volontary and built into the premise of the voter initiative process.

      The very idea of the government saying “Five hundred anonymous people have indicated they wish to present an initiaitive saying such and such” makes the hair on the back of my neck stand up.Report

      • wardsmith in reply to North says:

        By all means the AUTHOR of the initiative should be public (and is) but do we want every single signer of same to be placed in the same category as author? Most folks signing a petition think they are doing a public good and most initiatives are fairly mundane. However the “chilling” thing here is exactly what I alluded to in the original Q&A with Burt (once I got him to play). Also the OP generally agrees, with the caveat that signing one of these puts you in the public eye, like it or not. Brilliant wordsmith that he is, Burt even did the fine play on chill and freezer, evoking can’t stand the heat and kitchen.

        Gorgias (sounds better, no?) points out a bigger concern about privacy in general, one I agree with. In point of fact I suspect our belief in “privacy” as a right, Roe V Wade notwithstanding is an illusion. We don’t really have a right to privacy, just a wish. And even that wish is being eroded daily.Report

        • Patrick Cahalan in reply to wardsmith says:

          If we’re talking about signatures to put an initiative on the ballot, Ward, there should in fact be a public posting.

          Once you decide to attempt to encode your opinion in the law, you ought to be willing to face the music.

          I’m sympathetic to the exception scenario Burt outlines, above, but in most practical circumstances signing off on a piece of paper isn’t going to get you fired or lose you clients, particularly when your actual vote is private.

          Shoot, I sign most petitions that anyone shoves in front of me, as long as it’s not completely oddball, including a bunch I would never vote for.  I’d happily defend that practice in front of anyone who wanted to take issue with it.Report

        • Patrick Cahalan in reply to wardsmith says:

          Not to mention that if you need 100,000 unique signatures of registered voters… how the hell are you going to verify that if you don’t publish it?Report

        • North in reply to wardsmith says:

          Ward I understand the value of privacy.. prize it in many ways. But in this context I just don’t feel it is pertinent. We’re talking about governance. There should be very little privacy or secrecy in governance.

          On a personal note having pondered it over, Gorigas, I disagree with you on one more thing specific to homosexuality. Privacy was definitely not to the movements benefit nor to the benefit of our kind. Privacy was where we went to disappear, privacy was the closet, it was where we went to die. Gay right has only advanced in the country when people have been willing to set privacy aside, voluntarily (as the signers of the petition do). Our collective welfare has only advanced when we were out, sympathetically trying to be conciliatory to our families, friends and peers but unapologetic about the truth of what we are.Report

          • Alan Scott in reply to North says:

            You’re absolutely right about privacy hurting gay rights.  And it’s also worth noting that contra Gorgias’s suggestion, intimidation was never really the point (or at least not the stated point) of Know Thy Neighbor.

            Per the mission statements, the point wasn’t to chill speech but to foster it.  The point of know thy neighbor wasn’t to have a list full of random strangers for us to hate on.  It was to have a list of people we know, but whose opinions we didn’t, that we could be visible for, whose minds we could possibly change.

            We weren’t supposed to threaten or shun people on the list so much as guilt trip them.Report

            • DensityDuck in reply to Alan Scott says:

              “We weren’t supposed to threaten or shun people on the list so much as guilt trip them.”

              So we’ll not use emotional influence and instead…use emotional influence?

              If people are afraid to openly express their opinions, then making political donations non-anonymous is not going to change that. It’ll just make people do the donation differently, i.e. form some kind of nonprofit shell company and donate to that. I could certainly see a Jewish synagogue saying that it’s historically been a bad idea for the government to have a names-and-address list of every Jew in town.Report

              • North in reply to DensityDuck says:

                We’re not talking about political donations Density, we’re talking about petition/initiaitive signing which involves (to a small degree) a given signer literally laying their hands on the wheels of the country/state/municipality’s governance. Any assumption of privacy flies out the window at that point.Report

  7. Kolohe says:

    This is a little trolly but I can’t figure out to put it any other way

    But you can’t have it both ways. The words “public” and “private” are opposites. If you want to speak publicly, you must do so in public, and doing so is inherently not private.

    Burt Likko is the pseudonym of an attorney in Southern California

    Even with your copious disclaimer appended, isn’t this a bit contradictory?Report

    • Pat Cahalan in reply to Kolohe says:

      Not really.

      As it stands, we can take Burt’s legal writings as that of a talented amateur since he won’t provide bona fides.  But they’re interesting and cogent reading anyway.

      I’m not going to hire Burt Likko to represent me in court.  I might hire the man behind the name, but that’s different 🙂Report

      • Jonathan in reply to Pat Cahalan says:

        I think Kolohe brings up an interesting point. There is an apparent contradiction, if nothing more. My gut tells me the comparison is quite right, but I don’t think it can be easily dismissed.

        And, to be clear, I am not suggesting Burt needs to drop the pseudonym.Report

        • Patrick Cahalan in reply to Jonathan says:

          Posting anonymous flyers to convince people to sign a petition is public speech, but it’s not public-in-the-sense-of-actually counting as participation in the process of creating a new law.Report

    • Burt Likko in reply to Kolohe says:

      Changing minds is qualitatively different than changing laws. One is persuasion; the other compulsion. My ideas are valid regardless of my identity; the law demands obedience. Different standards appropriately apply in different arenas.

      I think about a half dozen LOOG bloggers and sub-bloggers know my real identity anyway despite the tissue of my pseudonym. On a cheekier level and intended in fun, what’s a “Kolohe” anyway?Report

  8. BSK says:

    “If the proprietor of that Apple store (I don’t know if it’s the corporation or a franchise or whatever) wants to discriminate against customers on the basis of partisan affiliation, I can find no law saying they cannot. It’s not treated the same way as an immutable characteric like race or sex. Or religion, which in theory is a mutable characteristic.”

    Something I’ve wondered for a long time is what separates political/social/personal ideology from religion?  Presumably, an employer can fire someone for being a Neo-Nazi but not for being a Christian.  Well, what if Neo-Nazis branded themselves as a sect of Christianity or as an entirely new religion all together?  Would they now enjoy those same protections?  How does the government define “religion”?  Personally, I’m weary of giving the government too much discretion in this area, since deciding what is and is not a religion is an incredibly powerful wand to wave because of the unique protections and privileges afforded religious groups.Report

  9. DensityDuck says:


    E.D. Kain was against anonymity, Jaybird was in favor.Report

  10. James Hanley says:

    Good post as usual, counselor.    If I could add one, I don’t think the distinction between privacy in speech and in voting was sufficiently fleshed out.  We have privacy in voting not to protect voters privacy per se, but to prevent corruption.  It’s very tempting to buy votes if you can verify what you’re purchasing, but buying votes becomes a really risky investment when you can’t verify whether you’ve actually bought the vote you wanted or whether the voter you paid actually casts the vote for someone else after all.

    Contra voting, that kind of corruption is not made more likely by open-ness in speech.  In fact quite the opposite–the main concern about anonymous political spending by private parties is that it makes corruption more likely (is Senator Smith bought and paid for by GloboCorp?).  I favor no limits on campaign donations or private spending, but I believe in requirements to name the names of the real individuals or corporations donating the money–not political front organizations, but those that wrote the checks to those political fronts.

    But stepping aside from direct campaign contributions or third-party campaign spending, I also think there can be no right to privacy in political debate in a democracy.  When people are engaging in debate about public policy they have stepped into the public arena, and when you do so you have voluntarily made yourself a public actor and can no longer claim the mantle of being private.

    The real drive behind these efforts is a desire to have an effect on other people through public policy without having to accept any consequences for your actions.  It’s claiming that “I have a right to try to raise someone’s taxes/reduce someone’s welfare payments/control their lives in some way or another,” but they shouldn’t have the right to make a direct objection to me personally.  That’s not particularly admirable anyway.Report

    • DensityDuck in reply to James Hanley says:

      “The real drive behind these efforts is a desire to have an effect on other people through public policy without having to accept any consequences for your actions.”

      But insisting on transparency is that, as well. If someone is worried that, because their donations cannot be anonymous, they might get fired for donating to Democrats, then they’re less likely to donate to Democrats.Report

      • North in reply to DensityDuck says:

        Insisting on transparency is a call to accountability, a vaccine against corruption and a prod towards careful deliberation.

        As for the theoretical consequences of someone donating the dynamic would presumably be the same with republicans so I don’t see the significance.Report

        • DensityDuck in reply to North says:

          Fair enough, but just be aware that “there’s no downside to transparency” is not a completely-true statement.Report

          • North in reply to DensityDuck says:

            I’m not saying there’s no downside, just that it’s the lesser of the two downsides.Report

            • DensityDuck in reply to North says:

              If we’re against something because of the mere existence of a downside, then isn’t “there’s still a downside” an argument against the proposed alternative?Report

              • North in reply to DensityDuck says:

                 Yes, I suppose it would be, but lest you forget: the current policy, the current status quos is that signers of petitions names and info is in the public record and is publicly disclosed. The onus is on those who would conceal this information to prove that it is preferable to do so both in practical terms and on principled terms. I would submit that they fail on both. You can offer only a consequentialist argument of fear of retaliation which hasn’t been a significant issue in the past on this matter or other matters. Meanwhile in principal and legally it’s an utter route in favor of the information remaining public.Report

    • Burt Likko in reply to James Hanley says:

      When people are engaging in debate about public policy they have stepped into the public arena, and when you do so you have voluntarily made yourself a public actor and can no longer claim the mantle of being private.

      So do you disagree with the distinction I drew above in response to Kolohe’s question?Report

      • North in reply to Burt Likko says:

        Isn’t that, in essence, a consequentialist position Burt? I mean it’s awful, sure, and a given voter should weigh their options and positions before making that step but I see allowing anonymous signing as a cure that is worse than the disease.Report

    • Mike Schilling in reply to James Hanley says:

      I also think there can be no right to privacy in political debate in a democracy.  

      Publius might disagree with that.Report

  11. Back when the legislature of the state where I live (and used to practice) was debating SSM, I testified publicly on its behalf as the official representative of my professional organization, which supported the SSM legislation. Given the immense controversy surrounding the issue, the legislative hearing was in a huge auditorium in the state capital with large numbers of people representing both sides of the debate. Since I was testifying on behalf of a respected medical association, my testimony was used prominently afterward by various groups supporting SSM, including links to the video on YouTube.

    As I went back to sit down with my confreres after I spoke, several people came up to me to 1) question the legitimacy of my claims to be speaking on behalf of the organization or 2) question my professional credentials. I responded cordially to them, and directed them to the appropriate places to verify both. Then I braced myself for public reprisal, which never materialized.

    It is my expectation that people who wish to influence a public debate do so publicly. IIRC, even Scalia (who doubtless breaks out into hives whenever he considers SSM) seemed to share this viewpoint when the issue was argued recently. People who want to exercise their free speech but hide their role in doing so seem to want to both have and eat their cake.Report

  12. Mike says:

    “Even the notorious Citizens United decision is not controversial because it considers campaign donations acts of free speech, but rather because it affords those free speech rights to corporations.”

    No, it’s considered controversial because donations of more than the small amounts normally limited by law are seen by anyone with a functional brain for what they are: acts of political bribery.Report