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United States v. O'Brien

Supreme Court of the United States · 1968 · Constitutional Law
Constitutional LawFirst Amendmentsymbolic speechcontent-neutral restrictionexpressive conductsymbolic speechdraft card burningcontent-neutral regulation

Facts

On March 31, 1966, David Paul O'Brien and three companions burned their Selective Service registration certificates on the steps of the South Boston Courthouse before a crowd. After being advised of his rights, O'Brien told FBI agents that he had burned his certificate because of his beliefs and knowing that he was violating federal law. He did not dispute that he burned the certificate and argued that he did so publicly to influence others to adopt his antiwar views. He was prosecuted under a 1965 amendment making it a crime knowingly to destroy or mutilate a Selective Service registration certificate.

Issue

Whether the 1965 amendment prohibiting the knowing destruction or mutilation of Selective Service certificates violated the First Amendment, either as applied to O'Brien's burning of his draft card as expressive conduct or because Congress allegedly enacted the law to suppress speech.

Rule

When speech and nonspeech elements are combined in the same course of conduct, a government regulation is sufficiently justified if it is within the constitutional power of the Government, furthers an important or substantial governmental interest, the governmental interest is unrelated to the suppression of free expression, and the incidental restriction on alleged First Amendment freedoms is no greater than is essential to the furtherance of that interest. An otherwise constitutional statute will not be struck down on the basis of an alleged illicit legislative motive.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Congress requires every person enrolled in a new federal emergency-response reserve to keep an official status card intact because the card is used to verify enrollment and contact information. At a protest in Denver, Maya Benton tears up her own card on a livestream to criticize federal disaster policy and is prosecuted under a statute making it a crime knowingly to destroy any such card.

Maya argues that her prosecution violates the First Amendment because she destroyed the card to convey a political message. What is the strongest response?

Explanation. When speech and nonspeech elements are combined in the same conduct, the regulation is valid if it is within governmental power, furthers an important or substantial interest, the interest is unrelated to suppressing expression, and the incidental restriction is no greater than essential. A law prohibiting knowing destruction of an official card used for administrative purposes regulates the noncommunicative impact of making the card unavailable, even if the defendant intended to express a message.