The misuse of Citizens United in bemoaning Scott Walker's recall victory.

Michael McConnell — the Stanford lawprof and former federal judge — has a fine op-ed in the Wall Street Journal. The effect of Citizens United "was almost exactly the opposite of" what anti-Walkerite pundits like the Greg Sargent and Lawrence O'Donnell have been saying.

Labor unions poured money into the state to recall Mr. Walker. According to the Center for Public Integrity, the NEA (National Education Association), the nation's largest teachers union, spent at least $1 million. Its smaller union rival, the AFT (American Federation of Teachers), spent an additional $350,000. Two other unions, the SEIU (Service Employees International Union, which has more than one million government workers) and Afscme (American Federation of State, County and Municipal Employees), spent another $2 million. Little or none of these independent expenditures endorsing a candidate would have been legal under federal law before Citizens United.

By contrast, the large spenders on behalf of Mr. Walker were mostly individuals. According to the Center for Public Integrity, these included Diane Hendricks, Wisconsin's wealthiest businesswoman, who spent over half a million dollars on his behalf; Bob J. Perry, a Texas home builder, who spent almost half a million; and well-known political contributors such as casino operator Sheldon Adelson and former Amway CEO Dick DeVos, who kicked in a quarter-million dollars each. Businessman David Koch gave $1 million to the Republic Governors Association, which spent $4 million on the Wisconsin race.

These donations have nothing to do with Citizens United. Individuals have been free to make unlimited independent expenditures in support of candidates since the Supreme Court case of Buckley v. Valeo (1976).

And this is the pattern we should expect generally, McConnell says, because business corporations don't want to offend customers by putting their names on partisan advertising. It's the unions that don't mind associating their names with one party — the Democratic Party. Sure, those rich individuals who get their money working for corporations can spend all they want, but recognition of their right to do that pre-dated Citizens United by more than 4 decades.