White also argued that states have the ability to prevent threats from corporate entities to the political process. "The State need not permit its own creation to consume it," White wrote. White noted that the nation had a history of recognizing the need to limit the influence of corporations in the political process, citing "United States v. Auto Workers", in which the Court held that the primary purpose of a federal act was "to avoid the deleterious influences on federal elections resulting from the use of money by those who exercise control over large aggregations of capital."