In United States v. Alvarez, 132 S. Ct. 2537 (2012), the defendant was convicted under 18 U.S.C. 704(b) for falsely claiming that he had received the Congressional Medal of Honor. 132 S. Ct. at 2542. The defendant challenged his conviction on the ground that 704(b) was a content-based suppression of pure speech and therefore facially unconstitutional under the First Amendment. Id. at 2543. The Supreme Court agreed, and invalidated 704(b) as facially violating the First Amendment, though no rationale commanded a majority. A four-justice plurality agreed that false speech was generally entitled to protection under the First Amendment, id. at 2547, and held that 704(b) was a content-based restriction subject to the most exacting scrutiny, id. at 2547-48. Applying this test, the plurality held that 704(b) did not survive strict scrutiny because the government had not carried its burden of showing that there was a close fit between the restriction imposed and the injury to be prevented or that the government had chosen the least restrictive means available to achieve its ends. Id. at 2550-51.