Brown, a tall and boisterous self-promoter barely in this thirties, was convinced after Bork’s defeat that attack politics was the only way for conservatives to reach the Court. “In the Bork fight I watched the conservative movement take a pass card and not fight,” he recalled. “After the Bork battle I said, I’m going to form an organization and be ready for the next one. I felt we had to approach these nomination fights like they were political battles, to be aggressive and fight the battle on enemy turf.” Even before there was another opening on the Court, he formed a group called Citizens United in preparation for the next nomination fight. If nothing else, a bruising confirmation battle would prove an enormously useful way of energizing conservative donors and invigorating his mailing list.
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