In United States v. Albertini, 472 U.S. 675, 684, 105 S.Ct. 2897, 2904, 86 L.Ed.2d 536 (1985), a peace activist who had been issued a bar letter nine years earlier for destroying secret Air Force documents at Hickam Air Force Base was convicted of violating 18 U.S.C. Sec. 1382 when he reentered the base to attend an open house celebration. Prior to his arrest, the activist was engaged in a peaceful demonstration protesting the nuclear arms race. Albertini, 472 U.S. at 678, 105 S.Ct. at 2901. In upholding the activist's conviction, the Supreme Court characterized as "dubious" the Ninth Circuit's conclusion that Hickam was a temporary public forum during the open house. Id. at 686, 105 S.Ct. at 2905. The Court reaffirmed its narrow reading of Flower and emphasized that a military base does not become a public forum "merely because the base is used to communicate ideas or information during an open house." Id. at 686, 105 S.Ct. at 2905. The Court further noted that although the district court did not make any explicit findings concerning the degree to which Hickam Air Force Base was accessible to the public during the open house, the record did not indicate "that the military so completely abandoned control that the base became indistinguishable from a public street as in Flower. Id. In Albertini, the Court did not decide whether the base became a public forum. Instead, it proceeded to address the First Amendment question premised on the reasonableness of enforcing a bar order issued because of the defendant's prior criminal activity.