With their ability to out source and robo source their labor inputs, many corporations no longer have the same incentive to support improvements in national education systems and other measures that would enhance labor productivity in their home nations. And with the astonishing increase in trade and investment flows, multinational corporations are playing a far more significant role than ever before, Some political scientists have asserted that the influence of corporations on modern governance is now almost analogous to the influence of the medieval church during the era of feudalism Justice Powell wrote decisions creating the novel concept of “corporate speech," which he found to be protected by the First Amendment. This doctrine was then used by the court to invalidate numerous laws that were intended to restrain corporate power when it interfered with the public interest. In 1978, for example, Powell wrote the opinion in a 5-4 decision that for the first time struck down state laws prohibiting corporate money in an election (a citizens referendum in Massachusetts) on the grounds that the law violated the free speech of "corporate persons. Thirty-two years later, the U.S. Supreme Court relied on Powell's opinion to allow wealthy individual donors to contribute unlimited amounts to campaigns secretly, and further expanded the 1886 Southern Pacific precedent declaring corporations to be persons