Montana's I-194 Would Test Corporate Law to Limit Political Spending

Montana voters will decide in November 2026 whether to bar corporations, unions and other artificial persons from spending money on state politics.
The proposal is listed as Initiative 194 (I-194), titled the "Exclude Political Spending from Artificial Persons’ Charter Powers Initiative (2026)." Ballotpedia The listing appears in the state's 2026 ballot measure records.
NPR reported on the measure on Oct. 13, 2026, in a report titled "Montana ballot measure could undo ruling on corporate spending in state politics." NPR The report by Aaron Bolton aired as part of Morning Edition for Oct. 13, 2026, and was published at 4:45 a.m. ET that day.
As described in September reporting, the measure would address corporate and anonymous money in politics tied to the Citizens United court ruling. It would bar corporations, unions and other "dark money" sources from political spending, where the donor behind the money is not disclosed. Reuters Reuters first reported the proposal on Sept. 16, 2026, describing it as a revolt against corporate money that could reshape politics.
The proposal is also known as the Montana Plan. In audio coverage, the plan was described as aiming to eliminate corporate-type spending in Montana by sidestepping a controversial U.S. Supreme Court ruling. A separate Reuters video description said the November vote will decide whether Montana becomes the first state to bar corporations from spending money on politics.
The title points to how it would work. It does not set a standard spending limit. It would exclude political spending from the charter powers of artificial persons. Think of charter powers like a permission slip from the state that lists what a corporation or union is allowed to do.
The broader context here is why the drafters used corporation law instead of election law. Citizens United rests on First Amendment protection for independent political spending, meaning spending not controlled by a candidate. A charter-powers rule tries to change the question from speech restriction to state-granted corporate authority. For election lawyers, that difference will shape the legal briefs. The state will argue it is defining what a corporation is empowered to do. Opponents will argue it is blocking protected spending under a different name.
Looking at what this means for practitioners, three pressure points stand out. The first is scope, since the measure names artificial persons, a term that in Montana practice covers corporations and unions. The second is disclosure and enforcement, since a spending ban still needs a definition of political spending, a regulator to apply it, and a remedy that can survive court review. The third is preemption and severability, since if a court says the rule cannot apply to independent expenditures, the question becomes what, if anything, is left in effect.
Looking ahead to the vote, it is set for November 2026. If approved, litigation in federal court is certain. If rejected, the charter-powers model will still have been tested at the ballot box.


