This is the central problem with Citizens United. The supreme court tends to be unusually deferential with 1A cases and ruled that infinite money can go into formally unaffiliated PACs. Undoing this would require activist judges or a constitutional amendment.
The supreme court is majority activist judges. Why cant new judges undo the old activist judges wrongly decided law? Why are the other new judges suddenly activists?
In the case of Citizens United, it's actually a pretty straightforward case. Without a constitutional amendment, it would take a very unorthodox reading of the first amendment.
The "problem" with Citizens United is that it's a very clear case.
