In Turney v. State, 922 P.2d 283, 291 (Alaska Ct. App. 1996), the defendant demonstrated on behalf of the Fully Informed Jurors Association at the Fairbanks, Alaska, courthouse. Turney engaged in activities such as yelling with his bullhorn, bleating at prospective jurors like a sheep, and beating on doors. Upholding Turney's conviction for disorderly conduct, the court observed that if it accepted the argument that the defendant's activities were absolutely protected by the First Amendment, it would mean that, for instance: "a protester could station himself on the street outside a political opponent's window and shout all night through an amplifier without violating the disorderly conduct statute (as long as he was shouting about political or social issues). Similarly, a protester could use a bullhorn in the hallways of a courthouse to disrupt court proceedings throughout the day." (Turney, 922 P.2d at 290.) As the Turney court noted, "there is a crucial difference between engaging in speech that is protected by the First Amendment and 'exercising . . . protected first amendment rights.'" Id. at 291. Political speech may be protected by the Constitution, but the government retains a limited power to regulate the exercise of that speech in a reasonable manner. Id.