Lloyd Corp. v. Tanner

In Lloyd Corp. v. Tanner (1972) 407 U.S. 551, the United States Supreme Court noted that the First Amendment imposes limitations "on state action, not on action by the owner of private property used nondiscriminatorily for private purposes only." ( Id. at p. 567 92 S. Ct. at p. 2228.) In Lloyd the court held a group of individuals protesting the Vietnam War had no First Amendment right to leaflet at a large, private shopping center. The court stated property does not "lose its private character merely because the public is generally invited to use it for designated purposes." ( Id. at p. 569 92 S. Ct. at p. 2229.) Rather, only private property which has been "dedicated . . . to public use" is subject to First Amendment limitations. ( Id. at p. 570.)