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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 ConstitutionAleft most of the powers to local governments where factions are unlikely to formBplaced financial limits on factions to prevent them from creating problemsCcreated an independent judiciary that would prosecute those forming factionsDcreated a large republic with many factions that would cancel each other out

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