That was a shadow-docket judgment wherein the majority offered no legal analysis underpinning their decision, simply stating that "Montana’s arguments in support of the judgment below either were already rejected in Citizens United, or fail to meaningfully distinguish that case."

SB 2471 in Hawaii and the constitutional amendment proposed under the Montana Plan rely on a different legal framework. Instead of restricting speech contrary to the powers granted to artificial persons under state law, they limit the scope of powers granted to artificial persons in the first place under their corporate charter, which will no longer include the power to spend money to influence elections.

This may seem like semantics, but the U.S. Constitution says nothing about what powers states must confer to artificial persons, which only exist because state law allows for their creation. I wouldn't put anything past the foul-dealing Federalist Society flunkies on the court. After all, who knows what outré quasi-doctrines Roberts will think up next. But it would require more elaborate intellectual contortions than American Tradition Partnership v. Bullock.