Something can be an appendage to a right. But it does not mean the government has an obligation to afford it the same protections as the right itself. Effective communication of political ideals also requires access to airways, printing presses, campaign staff, etc. But the government has no obligation to treat access to these as a Constitutional, inviolable right, on par with one’s freedom to say what she pleases.  An expression of an opinion is protected strictly by the letter of the law. However, the Citizen's United decision effectively expands this protection to two new entities: 1) non-person and 2) act of spending. Rather than reinterpreting current legislation that protects free speech, new laws ought to be created seeking to protect these two entities from committing to political expressions. And, this has to be exercised through the legislative branch rather than judicial.  With the Citizen's United decision, the judicial branch is effectively writing new legislation that is 1) recognizing corporate entities to have same political expression rights as citizens/individuals and 2) redefining the act of spending to be the same as an expression of an opinion as well as an act of demonstrating an expression of an opinion.