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American Library Association v. United States

Supreme Court of the United States · 2003 · Constitutional Law

Constitutional LawFirst AmendmentSpending ClausePublic Forum DoctrineUnconstitutional ConditionsCIPAChildren's Internet Protection Actlibrary filtering

Facts

Congress enacted the Children's Internet Protection Act (CIPA) after learning that public library patrons, including minors, were using library Internet terminals to access pornography and that pornographic images were being exposed to staff, passersby, and children. CIPA conditions a public library's receipt of E-rate and LSTA federal assistance for Internet access on use of a technology protection measure that blocks visual depictions constituting obscenity or child pornography, and blocks material harmful to minors from minors. The statute also permits disabling the filter to enable access for bona fide research or other lawful purposes, and under the E-rate program disabling is permitted during adult use. Library associations, libraries, patrons, and Web site publishers challenged the statute facially under the First Amendment.

Issue

Whether Congress, consistent with the First Amendment and the Spending Clause, may condition public libraries' receipt of federal Internet-access subsidies on their installation and use of filtering software that blocks obscenity, child pornography, and material harmful to minors. Also, whether those conditions create an unconstitutional condition or induce libraries to violate patrons' First Amendment rights.

Rule

Congress has broad latitude under the Spending Clause to attach conditions to federal assistance to further policy objectives, but it may not induce recipients to engage in conduct that would itself be unconstitutional. In determining whether a public library's Internet filtering violates the First Amendment, public forum analysis does not apply because public library Internet access is neither a traditional nor a designated public forum, and libraries retain broad discretion to make content-based judgments about what material to provide in furtherance of their traditional missions. When the government funds a program, it may define the limits of that program by insisting that public funds be spent for the purposes for which they were authorized.

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Congress creates grants for municipal media centers in Denver and Phoenix to subsidize public computer stations. To receive the money, a center must install software that blocks visual depictions of obscenity and child pornography, while allowing staff to disable the filter for lawful uses. The Riverfront Media Center argues the condition is invalid because accepting the funds would force it to violate patrons' First Amendment rights.

How should a court rule under the governing doctrine?

Explanation. Congress has broad latitude to attach conditions to federal assistance to further policy objectives, but it may not induce unconstitutional conduct. The lead opinion held that requiring filters for subsidized public Internet access did not induce a constitutional violation because the access point was not a public forum and the recipient retained discretion similar to collection selection. The same reasoning supports the condition here.