In City of Ladue v. Gilleo, 512 U.S. 43, 129 L. Ed. 2d 36, 114 S. Ct. 2038 (1994), the Court took a somewhat different approach in determining whether a city's ordinance that prohibited all signs within city limits, except those that fell within ten limited exemptions, was constitutional. Gilleo challenged the ordinance because it prohibited her from displaying a sign in the window of her home stating, "For Peace in the Gulf." In analyzing the ordinance, the Court noted that "exemptions from an otherwise legitimate regulation of a medium of speech may be noteworthy for a reason quite apart from the risks of viewpoint and content discrimination: They may diminish the credibility of the government's rationale for restricting speech in the first place." Id. at 52. In examining the city's "near-total" prohibition of residential signs, the Court assumed arguendo that the ordinance was free of impermissible content or viewpoint discrimination. Id. at 53. Instead, the Court first asked whether the city could properly prohibit Gilleo from displaying an antiwar sign at her own home. Then the Court stated that, only if necessary, would it consider whether it was improper for the city simultaneously to permit certain other signs. Id. The Court focused on the fact that the ordinance affected residential property and concluded that the ordinance went too far in banning speech because it did not leave open adequate alternative channels of communication. In concluding that the ordinance violated the First Amendment, the Court emphasized the special status of speaking from one's own home: A special respect for individual liberty in the home has long been part of our culture and our law. . .; that principle has special resonance when the government seeks to constrain a person's ability to speak there. . . . Most Americans would be understandably dismayed, given that tradition, to learn that it was illegal to display from their window an 8- by 11-inch sign expressing their political views. Whereas the government's need to mediate among various competing uses, including expressive ones, for public streets and facilities is constant and unavoidable, . . . its need to regulate temperate speech from the home is surely much less pressing. Id. at 58 The Court said that the exemptions in the ordinance at issue in that case shed light on whether too much speech was prohibited and diminished the credibility of the government's rationale for restricting some types of speech but not others: Exemptions from an otherwise legitimate regulation of a medium of speech may be noteworthy for a reason quite apart from the risks of viewpoint and content discrimination: They may diminish the credibility of the government's rationale for restricting speech in the first place. . . . In this case, at the very least, the exemptions from Ladue's ordinance demonstrate that Ladue has concluded that the interest in allowing certain messages to be conveyed by means of residential signs outweighs the City's esthetic interest in eliminating outdoor signs. Ladue has not imposed a flat ban on signs because it has determined that at least some of them are too vital to be banned. Id. at 52-53 The credibility of the Texas Act is diminished by the exemptions that it permits. The exemptions in City of Ladue were not enough, however, standing alone, to persuade the Supreme Court that the prohibition at issue was unconstitutional. The Court said that it would first "ask whether Ladue may properly prohibit the property owner from displaying her sign, and then, only if necessary, consider the separate question whether it was improper for the City simultaneously to permit certain other signs." The Supreme Court noted that Ladue's ordinance, like the Texas Act, "covers even such absolutely pivotal speech as a sign protesting an imminent governmental decision to go to war." And, the Ladue ordinance, like the Texas Act, foreclosed a "venerable means" of communication, which is displaying a sign on private property expressing the owner's political views: Ladue has almost completely foreclosed a venerable means of communication that is both unique and important. It has totally foreclosed that medium to political, religious, or personal messages. Signs that react to a local happening or express a view on a controversial issue both reflect and animate change in the life of a community. Often placed on lawns or in windows, residential signs play an important part in political campaigns, during which they are displayed to signal the resident's support for particular candidates, parties, or causes. They may not afford the same opportunities for conveying complex ideas as do other media, but residential signs have long been an important and distinct medium of expression. Id. at 54-55. The Supreme Court then noted that "our prior decisions have voiced particular concern with laws that foreclose an entire medium of expression," and that "by eliminating a common means of speaking, such measures can suppress too much speech." Placing a sign on one's own property is a common means of speaking, even if the property is not the owner's residence. The City of Ladue argued that it was merely regulating the time, place and manner of speech, and the property owner remained free to communicate by other means. The Supreme Court was unpersuaded: "We are not persuaded that adequate substitutes exist for the important medium of speech that Ladue has closed off." Id.