The decision of the United States Supreme Court in Citizens United v. Federal Election Commission, while dealing with the issues of the First Amendment and federal campaign finance, affirmed previous case law that characterized corporations as legal persons. While this case has great importance in the context of constitutional law and federal election law, the arguments and analysis presented may also apply to corporate criminal liability. This Article looks at Citizens United as well as a recent Tennessee Attorney General (TAG) opinion to explore their potential effect on the characterization of corporations as legal persons in the context of corporate criminal liability. The Author focuses on two potential approaches to determining corporate personhood in the context of corporate criminal liability, the potential all-or-nothing approach suggested by the Court in Citizens United versus the more nuanced approach suggested by the Stevens opinion in Citizens United and the TAG opinion. The Court’s opinion in Citizens United, a possible all-or-nothing approach, would leave little room for considering policy and theory arguments in determining that a corporation is a person in the context of corporate criminal liability. In contrast, the Stevens and TAG opinions would allow for a more flexible, and what this Author deems a potentially more desirable, approach to corporate personhood that involves consideration of theory and policy arguments in determining whether a corporation is a person for purposes of corporate criminal liability.