This ruling was frequently characterized as permitting corporations and unions to donate to political campaigns,[24] or as removing limits on how much a donor can contribute to a campaign.[25] However, these claims are incorrect, as the ruling did not affect the 1907 Tillman Act's ban on corporate campaign donations (as the Court noted explicitly in its decision[26]), nor the prohibition on foreign corporate donations to American campaigns,[27] nor did it concern campaign contribution limits.[28] The Citizens United decision did not disturb prohibitions on corporate contributions to candidates, and it did not address whether the government could regulate contributions to groups that make independent expenditures.[22] The Citizens United ruling did however remove the previous ban on corporations and organizations using their treasury funds for direct advocacy. These groups were freed to expressly endorse or call to vote for or against specific candidates, actions that were previously prohibited.[29] The ruling is also often incorrectly characterized as creating the idea that corporations may exercise speech rights, and that "corporations are people." Both notions are also incorrect. The Supreme Court has recognized that corporations, as associations of people, may exercise many of the rights of natural persons at least since Dartmouth College v. Woodward in 1819, and has recognized that corporations are protected under the equal protection clause of the 14th Amendment since Santa Clara County v. Southern Pacific Railway was decided in 1886. First Amendment protection for corporate speech has also been recognized since at least Valentine v. Christenson (1942), and in the realm of campaign finance since at least First National Bank of Boston v. Bellotti (1978). The question in Citizens United was simply whether the First Amendment protected the rights of corporations to engage in a particular form of corporate speech.[citation needed]