From the perspective of conservatives, Citizens United was an unnecessary decision. The Court had already held that corporations could spend unlimited amounts on political advertising with the intent and the effect of electing candidates of their choice, so long as they did not specifically use the magic words advocating the election or defeat of an candidate. Short of that, all-out attack ads regarding a candidate were fully protected by the Roberts Court. Permitting the use of the magic words added little of substance.
But the decision unleashed a political whirlwind against the role of business corporations in politics, and deep concerns about the integrity of the democratic process and the Court itself. Those concerns about the Court came home to roost in the most significant case of this term.
It is now widely perceived that the Chief Justice was forced to abandon the conservatives in order to uphold the core of the Affordable Health Care Act. He did that so that the reputation of the Court was not further tarnished. But if he had not lead the Court to the unnecessary opinion in Citizens United, he would have had more freedom to maneuver.
Now that he has upheld the Affordable Health Care Act, he is free for some time to enact his ideological agenda. Alas, this is not good news for the Voting Rights Act or affirmative action this coming term.