The decision in Citizens United v. Federal Election Commission (2010) led to the creation of super PACs that can legally raise unlimited amounts of money and engage in electioneering with few limits. Madison argued in The Federalist 10 that factions, like super PACs, would not be detrimental to society because the Constitution

James Madison believed that factions were not detrimental to Society because first they represented the interests of specific groups of people before society and before the federal government, and second, because if the country has many factions with different interest, these factions will have to negotiate and reach agreements that respect minority rights.