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See also First Amendment (public forum) '[T]he Court [has] identified three types of fora: the traditional public forum, the public forum created by government designation, and the nonpublic forum.' Cornelius v. NAACP Legal Defense & Ed. Fund, Inc., 473 U. S. 788, 802 (1985). Traditional public fora are defined by the objective characteristics of the property, such as whether, 'by long tradition or by government fiat,' the property has been 'devoted to assembly and debate.' Perry Ed. Assn. v. Perry Local Educators' Assn., 460 U. S. 37, 45 (1983). The government can exclude a speaker from a traditional public forum 'only when the exclusion is necessary to serve a compelling state interest and the exclusion is narrowly drawn to achieve that interest.' Cornelius, supra, at 800.
Designated public fora, in contrast, are created by purposeful governmental action. 'The government does not create a [designated] public forum by inaction or by permitting limited discourse, but only by intentionally opening a nontraditional public forum for public discourse.' 473 U. S., at 802; accord, International Soc. for Krishna Consciousness, Inc. v. Lee, 505 U. S. 672, 678 (1992) (ISKCON) (designated public forum is 'property that the ...
