A conservative organization called Citizens United made a documentary film critical of former Senator Hillary Clinton called Hillary the Movie. The official website for the film described its content: "If you want to hear about the Clinton scandals of past and present, you have it here!"http://www.usatoday.com/news/washington/judicial/2009-09-09-courtFEC_N.htm

On January 21, 2010, the U.S. Supreme Court ruled in favor of Citizens United, overruling two cases decided by the Rehnquist Court and striking down a provision of the McCain Feingold Act that limited corporate and union spending in political campaigns.http://www.nytimes.com/aponline/2010/01/21/us/AP-US-Supreme-Court-Campaign-Finance.html

The U.S. Supreme Court re-heard oral arguments in the case Citizens United v. Federal Elections Commission on September 9, 2009 in a special pre-term session. The Court's questioning during oral arguments indicated that the conservative majority of the Court would overturn campaign finance legislation regulating corporate spending on elections.http://www.usatoday.com/news/washington/judicial/2009-09-09-courtFEC_N.htm

Including a cast comprised of Ann Coulter, Newt Gingrich and Dick Morris, Hillary the Movie is comprised of nearly 40 interviews with people who have had policy differences and/or have reported on the former senator. According to the Federal Election Commission, The Christian Science Monitor reports, the film is considered a form of "electioneering communications", which means that both a disclaimer and the names of anyone who's funding the promotion would have to appear on the ads. Citizens United, which aimed to advertise the movie on television, argues that advertisements for the film constitute free speech. On Monday, March 24, 2008, The U.S. Supreme Court dismissed the film producers' appeal on the grounds that appeal should be dealt with at the level of the federal appeals court in Washington.