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the baseline to “dependence upon the people alone,” I don’t mean to be fixing upon any particular theory of what that representation should be. In particular, my formulation is meant to be agnostic between a “sanction model” of representation and a “selection model.” See Jane Mansbridge, “A ‘Selection Model’ of Political Representation,” Journal of Political Philosophy 17 (2009): 369. With both models, there is at least a moment when a representative is accountable. That moment establishes the dependency, however that dependency is expressed.

15. See John Armor, “Congress for Life,” Inner Self, available at link #110 (last visited June 21, 2011).

16. Robert L. Trivers, “The Evolution of Reciprocal Altruism,” Quarterly Review of Biology 46 (1971): 35.

17. Brooks, Corruption in American Politics and Life, 274.

18. Melvin Urofsky, Louis D. Brandeis: A Life (New York: Pantheon, 2009), 159.

19. Survey, Global Strategy Group (Jan. 11, 2011), on file with author. See also Hart Research Associates, “Protecting Democracy from Unlimited Corporate Spending: Results from a National Survey among 1,000 Voters on the Citizens United Decision” (2010) (finding that 95 percent strongly agree or somewhat agree that “[c]orporations spend money on politics to buy influence/elect people favorable to their financial interests”), 7. See also Eric Zimmermann, “Poll: 70 Percent Believe Congress Is Corrupt,” The Hill’s blog Briefing Room (Aug. 10, 2010), available at link #111 (reporting the results of a Rasmussen poll that “[v]oters are more likely to trust the integrity of their own representative, but not by much. A majority, 56 percent, think their own lawmakers can be bought”). See also “Poll: Half of Americans Think Congress Is Corrupt,” CNN (Oct. 19, 2006), available at link #112 (finding that, four years before the Rasmussen poll, 49 percent of Americans said “most members of Congress are corrupt” and 22 percent said their individual legislator was corrupt); “Distrust, Discontent, Anger and Partisan Rancor: The People and Their Government,” Pew Research Center (2010), 51, available at link #113.

20. Schram, “Speaking Freely,” 89.

21. Ibid., 31.

22. Ibid., 16.

23. Ibid., 23.

24. Larry Makinson, “Speaking Freely,” Center for Responsive Politics (2003).

25. Bill Bradley, “Government and Public Behavior,” Public Talk: Online Journal of Discourse Leadership, available at link #114.

26. Makinson, “Speaking Freely,” 44.

27. Ibid.

28. For a review, see Frank R. Baumgartner and Beth L. Leech, Basic Interests (Princeton, N.J.: Princeton University Press, 1998). F. R. Baumgartner, Jeffrey M. Berry, Marie Hojnacki, David C. Kimball, and Beth L. Leech, Lobbying and Policy Change: Who Wins, Who Loses, And Why (Chicago: University of Chicago Press, 2009), 320. See also Lowenstein, “On Campaign Finance Reform,” 307–8 (summarizing skeptics’ view).

29. Baumgartner, Berry, Hojnacki, Kimball, and Leech, Lobbying and Policy Change, 194.

30. Stephen Ansolabehere, John M. de Figueiredo, and James M. Snyder, “Why Is There So Little Money in U.S. Politics?” 105.

31. Ibid., 114; Stephen Ansolabehere, John M. de Figueiredo, and James M. Snyder, “Why is There So Little Money in U.S. Politics?” (Center for Competitive Politics, June 2002), 114, available at link #115.

32. Ansolabehere, Figueiredo, and Snyder, “Why Is There So Little Money in U.S. Politics?” (2003), 105.

33. Ansolabehere, Figueiredo, and Snyder, “Why Is There So Little Money in U.S. Politics?” (2002), 20

34. Ibid.

35. Ibid.

36. Center for Competitive Politics, “Fairly Flawed: Analysis of the 2009 Fair Elections Now Act (H.R. 1826 and S. 752),” Policy Briefing 2 (2009): 4.

37. As Richter and his colleagues write, “[T]he inordinate attention given to PAC contributions is essentially an exercise in ‘looking under the lamppost’ since PAC data have been readily available since the 1970s, whereas lobbying data have only become available recently… While focusing on contentious bills has its merits, crafty politicians have a variety of tools