There is broad agreement among both progressives and conservatives that a constitutional amendment will be required to overturn Citizens United. At this moment, Karl Rove, the Koch Brothers, and a handful of other billionaires have already bought enough members of Congress to render any resolutions, which simply call for Congress to amend the Constitution, ineffectual. Congress will never amend the Constitution on its own just because we ask nicely. 

Fortunately, the Constitution provides an alternate path for amending it, which is to have two-thirds of the states call for a constitutional convention. While attempts to use this method have never resulted in an actual convention, calls for a constitutional convention have played a vital role in many successful campaigns to amend the Constitution.

The 17th Amendment, requiring the direct election of Senators, is the perfect example of how a nationwide pro-democracy movement like ours can successfully leverage the imminent threat of a constitutional convention. In 1893, Nebraska was the first state to have its legislature call for a convention for the direct election of Senators. By the turn of the century, an additional nine states had followed suit and in 1913 the movement had come within one state of reaching the two-thirds threshold that would force a convention. When it became clear to Congress that the 17th Amendment was going to happen one way or another, members decided to preempt a convention by passing it themselves.

Having the states call for a convention to add the 28^th Amendment to the Constitution is the only way to present Congress with a consequence to its continued inaction. When we win it will be through strength, not through weakness.