The courts are now into determining if something is a "movie"

Because of campaign finance laws the courts are involved in determining whether a movie is a movie or a campaigns ad:

Citizens United had hoped to run the television advertisements in key election states during peak primary season. The court ruling means the group must either keep its ads off the air or attach a disclaimer and disclose its donors.

So do Michael Moore's movies rate being classified as a movie? Is it just that Moore's movies are being released in an odd numbered year? Can he promote it in any way during an election?