To take one prominent example, President Obama famously attacked the Citizens United case in his State of the Union address in 2010. Many observers were troubled by the president’s lack of decorum in not just taking such a harsh swipe at the Supreme Court—something that no president had done with such vigor for over seventy years—but in doing so with the justices sitting in front of him. The justices were barred by protocol from objecting in any way, and had to sit there quietly like children while the president scolded them. That’s no way, many critics argued, to treat a coequal branch of government. Not only that, but the president claimed that Citizens United “will open the floodgates for special interests, including foreign corporations, to spend without limit in our elections.” Justice Samuel Alito, agitated that the president inaccurately suggested that the case allowed foreign corporations to spend money on American elections, mouthed “not true.” Later that year, Obama senior adviser David Axelrod declared outright, and in an outright lie, that beneficiaries of Citizens United such as the “benign-sounding Americans for Prosperity, the American Crossroads Fund” are “front groups for foreign-controlled companies.”