Since 2010, when the case was decided, independent expenditures and other forms of outside spending have grown exponentially, according to OpenSecrets. In 2010, independent expenditures totaled $203.9 million; in 2016, it was $1.48 billion. In this nonpresidential year, with final reports still to come, independent expenditures totaled at least $1.18 billion.
The surge in outside spending unconstrained by contribution limits is a central element of current campaign finance practice.