[nickff]

The issue here seems to be that law enforcement agencies can compel disclosure of donor lists, even when there is no good reason. This is a different (but related) issue to Citizens United and other recent First Amendment cases, which have allowed organizations to keep donor lists non-public.

I think this case shows that Citizens United didn't go far enough in protecting anonymous speech.

[linkregister]

Anonymous speech was contemplated by the Justices during the deliberation of Citizens United. Justice Thomas's was the only dissenting opinion in upholding the reporting requirements for contributions toward PACs.

The majority and dissent opinions agree that the public interest is served by knowing who is funding a particular set of advertisements. Wrongful retaliation based off of that speech was deemed activity that should be handled when it occurs.