In Arkansas Educ. TV v. Forbes (1998) 523 U.S. 666, a state-owned public television station sponsored a debate between major party candidates for Congress, and excluded an independent candidate with little popular support. (Id. at p. 670.) The exclusion was not pursuant to a specific statute, ordinance, or regulation; it simply was an exercise of discretion by station officials. (Ibid.) The court concluded that the debate was not a public forum (id. at p. 680) and upheld the exclusion as "a reasonable, viewpoint-neutral exercise of journalistic discretion consistent with the First Amendment." (Id. at p. 683.)