There are two ways of infringing liberty: by police power or economic power. The latter can be exercised either directly or indirectly, by orienting the way people think, by addling their brains, by using the press (media, a la Fox News) to bias them in favor of special interests (think Koch Brothers and Citizens United).

Citizens United left this country open to the power of money. We now know the extent to which moneyed interests use the press to further their interests.