In 2012, during the first election cycle after the Citizens United ruling, conservative groups targeted three members of the Florida Supreme Court for removal.

Justices Barbara Pariente, R. Fred Lewis and Peggy Quince won retention votes but were forced into an expensive campaign to keep their seats. Each raised $500,000 and all benefited from $3.3 million in spending by a bloc of lawyers called Defend Justice from Politics, according to the Center for American Progress policy institute.