When Can Speech Be Restricted In a ''Public Forum'' ?

The respective limitations upon government regulation of speech within a forum depend on the particular nature of the forum. Perry Educ. Ass'n v. Perry Local Educators' Ass'n, 460 U.S. 37, 45-46, 74 L. Ed. 2d 794, 103 S. Ct. 948 (1983). A public forum is an area that has traditionally been devoted to assembly and public debate, such as a public street or a sidewalk. See id. In a public forum, speech may only be suppressed if it is necessary to achieve a compelling governmental interest. See id. When permitted, regulations restricting speech may consist only of reasonable time, place, and manner regulations that are narrowly drawn to achieve the governmental interest and leave ample alternative channels for expression. See id. at 46. A limited public forum is one that the government has opened for public expressive activity. See id. Speech in a limited public forum may be regulated in the same fashion as a traditional public forum as long as the limited forum remains open. See id. Finally, a nonpublic forum is one that neither traditionally nor by government action has become a forum for public communication. See id. In a nonpublic forum, speech may be restricted so long as the regulations are reasonable and do not attempt to suppress expression because of a public official's opposition to the speaker's views. See id.