This past Friday, Vermont became the first state to officially call for a federal constitutional convention to pass an amendment overturning Citizens United v. the Federal Elections Commission and McCutcheon v. the Federal Elections Commission. While the resolution, JRS 27, is not to be considered until there are enough states — two-thirds — with the same opinion as Vermont, to demand a convention, the resolution reflects an increasing intolerance to unlimited money in politics.

The Vermont resolution was lobbied for by “The Young Turks’” founder Cenk Uygur’s Wolf PAC. The PAC argues that failed attempts to pass campaign finance disclosure laws — such as the Disclose Act — and recent court actions — such as the United States Supreme Court’s decision not to hear Montana’s claim that it did not have to abide to Citizens United for state- and local-level elections — have proven that only a fundamental change to the government can resolve this issue.

“Wolf PAC believes that we can no longer count on our federal government to do what is in the best interest of the American people due to the unfettered amount of money they receive from outside organizations to fund their campaigns,” write Wolf PAC on its website. “We believe that we have no choice but to put an amendment in the hands of our State Legislators, who are not, at this moment in time, completely blinded by the influence of money and might actually do what 87% of the country wants … take away the massive influence that money has over our political process.”

While the Wolf PAC — according to the organization’s organizing director Mike Monetta — currently has ten states considering similar resolutions, this is not the first time the states have called for a repeal. California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maine, Maryland, Massachusetts, Montana, New Jersey, New Mexico, Oregon, Rhode Island, Vermont and West Virginia all passed resolutions calling for a constitutional convention toward repealing Citizens United, with Washington, D.C. and over 400 other municipalities issuing resolutions in opposition to the Supreme Court decision. Last week, Milwaukee County, Wis. voted to place a referendum seeking a constitutional amendment reversing Citizens United on the November ballot.

There has also been a move by the states to strip corporations of their status as “legal persons,” which has been used to justify that corporations have a constitutional right to free speech.

For these states, the problem with Citizens United is the fact that — as a federal court decision affecting federal law — it carries supremacy over state and local laws. At the time that Citizens United was decided, 24 states had laws that either prohibited or limited independent expenditures by unions and corporations. While some states voluntarily changed their laws, many states — including most Northeastern states — did not.

Citizens United v. the Federal Elections Commission removed donation limits to non-campaign coordinated political activities and groups — such as “social welfare” and issue-education groups — for corporations, groups and labor unions. McCutcheon v. the Federal Elections Commission eliminated the aggregate campaign donation limit — or the total one person could give in one electoral cycle to all candidates and parties — for individuals and groups.

Last week, New York state became the latest state to bow to Citizens United when a federal district court struck down the state’s limits on contributions to independent groups. The lawsuit was launched by a Republican group that wished to influence the New York City’s 2013 mayoral election and represents a crop of lawsuits aimed at reining in the holdouts to the court’s decisions.

“Regardless of what one may think of Citizens United, these lawsuits were an important effort to clarify the law in those states that did not amend their statutes after the decision,” said Marc Elias, an attorney for General Majority PAC. General Majority PAC was created last year by Senate Majority Leader Harry Reid’s (D – Nev.) longtime chief-of-staff Susan McGee as a means to raise funds for Democratic races. The PAC is responsible for successful legal challenges in New Jersey and Pennsylvania, forcing the states to comply with the Supreme Court decisions.

With the Democrats illustrating their willingness to “play the game,” it is unsure if a constitutional amendment or convention call can succeed in such a political environment. Even though the Senate Democrats have announced that there will be a vote on a constitutional amendment proposed by Sen. Tom Udall (D – N.M.) to overturn the Supreme Court’s campaign financing decisions, it is increasingly being felt that such efforts — which would likely fail under a Republican filibuster — are more a matter of show; an attempt for Democrats to hold the moral high ground while still benefiting from the decisions. Under such a situation, it may be that the only action that can be taken will be found at the states level.

Currently, Ohio and Florida are the only states that still have not-overturned campaign financing limitations on their books. Alabama, Iowa, Louisiana, Maryland, Montana, New Mexico, North Dakota, South Dakota, Texas, West Virginia and Wyoming do not have laws that either explicitly allows or bans super PACS, leaving the issue unsettled in these states.

Constitutional amendments must be passed by a minimum of two-thirds of both houses of Congress and three-quarters of the states. However, a constitutional convention — in which a new constitution can be drafted and approved — can be convened in lieu of congressional approval with two-thirds of the states’ consents.