[infamouscow]

Yes, had SCOTUS ruled differently in Citizens United, the scope of the ruling would have likely been narrowly focused.

Every time SCOTUS makes a ruling, there are thousands of extremely talented activist lawyers that immediate begin working on legal strategies to further expand a ruling in ways they believe are favorable to their political ends. You have to understand, there are lawyers who focus on specific justices and study the idiosyncrasies of their rulings/philosophy so they can reverse-engineer legal outcomes as they desire.

In United States v. Jones, Ginsburg and Thomas ruled that attaching a GPS tracker to a car and monitoring it was a Fourth Amendment search. Thomas believes physically attaching the device is a property trespass and constitutes a search. Ginsburg believed prolonged GPS surveillance violates a reasonable expectation of privacy.

Even though Ginsburg and Thomas are polar opposites, if you understand how they rule, you can still get the outcome you want with the right case.