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The Supreme Court has often faced the problem of applying the broad principles of the First Amendment to unique forums of expression. See, e. g., Consolidated Edison Co. v. Public Service Comm'n, 447 U.S. 530 (1980) (billing envelope inserts); Carey v. Brown, 447 U.S. 455 (1980) (picketing in residential areas); Schaumburg v. Citizens for a Better Environment, 444 U.S. 620 (1980) (door-to-door and on-street solicitation); Greer v. Spock, 424 U.S. 828 (1976) (Army bases); Erznoznik v. City of Jacksonville, 422 U.S. 205 (1975) (outdoor movie theaters); Lehman v. City of Shaker Heights, 418 U.S. 298 (1974) (advertising space within city-owned transit system). Even a cursory reading of these opinions reveals that at times First Amendment values must yield to other societal interests. These cases support the cogency of Justice Jackson's remark in Kovacs v. Cooper, 336 U.S. 77, 97 (1949): Each method of communicating ideas is 'a law unto itself' and that law must reflect the 'differing natures, values, abuses and dangers' of each method.
The uniqueness of each medium of expression has been a frequent refrain: See, e. g., Southeastern Promotions, Ltd. v. Conrad, 420 ...
