In 2008, Citizens United produced a documentary film highly critical of Hillary Clinton called "". Fearing prosecution from the FEC, the organization sought a declaratory judgment in federal court to assure their right to show the movie, leading ultimately to the Supreme Court decision in "Citizens United v. Federal Election Commission". It previously produced and screened advertisements attacking other Democrats, including Bill Clinton, John Kerry, and Al Gore. In the 1988 US presidential election, Citizens United ran an ad that used Willie Horton to attack Democratic nominee Michael Dukakis. The ad was described as racist by the progressive magazine "Mother Jones."