In April 1978, when the Supreme Court decided "First National Bank of Boston v. Bellotti," 31 states had laws regulating corporate spending on ballot initiatives. However, not all of these state laws were annulled by the Supreme Court ruling. Universal caps on donations for ballot initiatives as well as specific bans aimed to prevent "undue" corporate influence on referendums were still considered constitutional. Of these 31 states, 18 of them, including Massachusetts, had laws that would be considered unconstitutional after the "Bellotti" decision.