In Walker v. Texas Div., Sons of Confederate Veterans, Inc., U.S., 135 S. Ct. 2239, 192 L. Ed. 2d 274 (2015), the Texas Division of the Sons of Confederate Veterans ("SCV") submitted a proposal to the Texas Department of Motor Vehicles Board ("Board") for a specialty plate design featuring a graphic of the Confederate flag. The Board rejected the proposal on the ground that many people would find the design offensive. The SCV challenged that decision in federal district court, which entered judgment in favor of the Board. The Court of Appeals for the Fifth Circuit reversed, holding that "Texas's specialty license plate designs are private speech and that the Board, in refusing to approve SCV's design, engaged in constitutionally forbidden viewpoint discrimination." Walker, 135 S. Ct. at 2245. The Supreme Court granted Texas's petition for writ of certiorari and, in a 5 to 4 decision, reversed. The Court held that "specialty license plates issued pursuant to Texas's statutory scheme convey government speech," and, because "when government speaks, it is not barred by the Free Speech Clause from determining the content of what it says," there could be no First Amendment violation. Id. at 2245-46. The Court articulated three primary grounds for its holding. First, since 1928, when Idaho introduced a standard base license plate "proclaiming 'Idaho Potatoes' and featuring an illustration of a brown potato," "States have used license plate slogans to urge action, to promote tourism, and to tout local industries." Id. at 2248. Thus, by history and tradition, license plates have been used by State governments for government expression. Second, license plates are governmental in nature, as "is clear from their faces," id., and, by serving the dual governmental purposes of vehicle registration and identification, they "are, essentially, government IDs." Id. at 2249. Because "issuers of IDs 'typically do not permit' the placement on their IDs of 'messages with which they do not wish to be associated,'" id., "'persons who observe' designs on IDs 'routinely--and reasonably--interpret them as conveying some message on the ID issuer's behalf.'" Walker, 135 S. Ct. at 2249. Consequently, license plate designs "'are often closely identified in the public mind with the State.'" Walker, 135 S. Ct. at 2248. A vehicle owner who seeks a specialty plate likely "intends to convey to the public that the State has endorsed that message"; and will obtain a specialty plate, instead of simply affixing a bumper sticker to his vehicle, because "Texas's license plate designs convey government agreement with the message displayed." Walker, 135 S. Ct. at 2249. Finally, States exercise "direct control" "over the messages conveyed on their specialty plates." Id. In Texas, "the Board must approve every specialty plate design proposal before the design can appear on a Texas plate." Id. "Texas has effectively controlled the messages conveyed on specialty plates by exercising final approval authority over their selection." Id. (citations and internal quotation marks omitted). The Walker Court went on to observe that specialty plates do not fit within any of the fora recognized for private speech on government property, under the forum doctrine, a point that in its view lent additional support to their being government speech. Obviously, license plates are not a traditional public forum. The final authority the State of Texas wields over each specialty plate design "militates against a determination that Texas has created a public forum." 135 S. Ct. at 2251. Texas's "ownership" of each specialty plate design makes it "particularly untenable that the State intended specialty plates to serve as a forum for public discourse." Id. A nd the facts that license plates "traditionally have been used for government speech, are primarily used as a form of government ID, and bear the State's name," "indicate that Texas explicitly associates itself with the speech on its plates." Id. Finally, specialty plates are not a nonpublic forum for private speech because "Texas is not simply managing government property, but instead is engaging in expressive conduct." Id. The Walker Court made clear that its analysis and holding "concerned only . . . specialty license plates," and that it was not addressing whether messages on vanity plates are government speech. Id. at 2244.