Justice Stevens has authored a number of important majority opinions and dissents expounding upon the limits of the Free Speech Clause of the First Amendment. Justice Stevens is not a free speech absolutist. His opinions have been guided by an apparent desire to allow the government to impose reasonable restrictions on speech, while scrutinizing, particularly closely, instances in which the government bans specific modes of expression entirely. The primary areas in which Justice Stevens has authored controlling decisions are regulation of indecency over broadcast and the Internet, regulation of indecency in general, and commercial speech. Stevens has also authored important dissents in cases addressing the constitutionality of laws banning the burning of an American flag, and free association rights. This report discusses Justice Stevens's opinions in these areas. Perhaps the most famous free speech decision authored by Justice Stevens is Federal Communications Commission v. Pacifica Foundation . This case has come to be known as the "Seven Dirty Words" case or the "Filthy Words" case. The case arose out of an adjudication the Federal Communications Commission (FCC) had undertaken against Pacifica Foundation for broadcasting a monologue by the comedian George Carlin at 2 o'clock in the afternoon. In the monologue, Carlin repeatedly used seven particularly inflammatory words that "you couldn't say on the public ... airwaves." All parties agreed that the monologue was not obscene and did not fit the definition for obscenity. The case, thus, squarely presented to the court the question of whether the FCC could regulate speech over broadcast that is indecent, but is not obscene. Justice Stevens took a methodical approach to the opinion, breaking down the issue presented into four separate questions: (1) the scope of the Court's review; (2) whether the FCC's order was a form of illegal censorship; (3) whether the broadcast was, in fact, indecent, under the applicable law; and (4) whether the order violated the First Amendment. After finding that the Court must focus its review on the FCC's determination that Carlin's monologue was indecent, and that the FCC's action was not illegal censorship, Stevens analyzed the more difficult questions presented by the case. The statute being enforced by the FCC in this case was 18 U.S.C. § 1464 which forbids the utterance of "any obscene, indecent or profane language by means of radio communication." Justice Stevens observed that the statute is written in the disjunctive, implying that each word has a separate meaning. Despite the fact that 18 U.S.C. § 1461, containing similar language to ban "obscene, indecent, or profane" speech through the mail, had been construed by the Court to prohibit only obscene speech delivered through the mail, Stevens reasoned that Congress could not have intended the same standard to apply to different modes of delivering speech. Furthermore, Stevens found that the accepted definition of indecency does not require an appeal to prurient interest. Rather, the term indecent "refers to nonconformance with accepted standards of morality." With that definition in mind, Justice Stevens had little trouble deciding that the "Filthy Words" broadcast was indecent. The only question left for Justice Stevens to answer was whether restricting indecent speech over broadcast radio was constitutional under the First Amendment. Stevens concluded that it is. In making this determination, Justice Stevens paid particular attention to the unique nature of the broadcast medium when deciding that restricting indecent speech over broadcast stations did not violate the First Amendment. Context for Justice Stevens, in this case and subsequent cases, was key. Even though the speech at issue was undisputedly "vulgar, "offensive," and "shocking," Stevens found that the monologue at issue in the case may have been protected speech in some contexts. Stevens went so far as to include a transcript of the monologue in its entirety as an appendix to the opinion. However, Justice Stevens wrote that, though the monologue may be protected in some contexts, it was not "entitled to absolute protection under all circumstances." Stevens set forth to analyze the context in which the speech occurred to determine whether the FCC's action was appropriate. Justice Stevens went on to hold that restricting (but not banning) indecent speech over the broadcast airwaves is constitutional because (1) "the broadcast media have established a uniquely pervasive presence in the lives of all Americans" and (2) "broadcasting is uniquely accessible to children, even those too young to read." Stevens seemed concerned by the unwilling listener happening upon this "vulgar" broadcast, perhaps as he was channel surfing for a station in his car. Stevens noted that a warning prior to the broadcast would not protect that unwilling listener. The hour of the broadcast (2 p.m.) also concerned Justice Stevens, because children were more likely to be listening at that hour. Stevens stressed that these factors weighed heavily in the Court's decision to uphold the FCC's action, and that the Court was not endorsing a broad indecency ban. Stevens made clear that a host of variables would continue to be important to constitutionally restricting indecent speech including time of day, the medium of delivery, and the content of the program. This opinion is widely cited and remains precedent for many decisions related to speech over the broadcast airwaves. Stevens's conviction that the broadcast medium is special carried over into his dissent in FCC v. League of Women Voters . In that case, Justice Stevens would have voted to uphold a statute that banned broadcast stations that received public funds from editorializing. Stevens expressed concern for the unseen influence of government funding upon the editorial opinions of stations that receive the funds. In his estimation, it was a legitimate concern for Congress to address. Furthermore, he noted that broadcasting was unique in that it is the only mode of mass communication that requires a license from the federal government. In his view, the proper course would have been to uphold Congress's attempt to prevent some non-commercial broadcast stations, whose license to operate and funding depend upon the federal government, from potentially becoming propaganda purveyors should the government choose to pressure those stations to broadcast the government's view as the station's own in an editorial. Consistent with the philosophy exhibited in the broadcast cases that context and form of speech factors heavily in the government's ability to restrict speech, Justice Stevens authored the opinion for the majority of the Court in Reno v. American Civil Liberties Union . The case struck down for violating the First Amendment two provisions of the Communications Decency Act (CDA) that prohibited indecent speech to minors on the Internet. Stevens wrote that the "burden on adult speech is unacceptable if less restrictive alternatives would be at least as effective in achieving the legitimate purpose that the statute was enacted to serve," making clear that a higher standard of scrutiny would apply to restrictions of speech on the Internet than restrictions of speech over broadcast. Stevens continued: "[T]he governmental interest in protecting children from harmful materials ... does not justify an unnecessarily broad suppression of speech addressed to adults. As we have explained, the Government may not 'reduc[e] the adult population ... to ... only what is fit for children.' " In distinguishing between the Internet and other forms of mass communication, Stevens found that "[t]he CDA's broad categorical prohibitions are not limited to particular times and are not dependent on any evaluation by an agency familiar with the unique characteristics of the Internet." Thus the restrictions on indecent speech over broadcast media were more narrowly tailored than the speech restriction in this case. Furthermore, Stevens took issue with the fact that the CDA imposed criminal penalties, and the Court has never decided whether indecent broadcasts "would justify a criminal prosecution." Lastly, in Steven's estimation, radio and television, unlike the Internet, have, "as a matter of history ... received the most limited First Amendment protection ... in large part because warnings could not adequately protect the listener from unexpected program content.... [On the Internet], the risk of encountering indecent material by accident is remote because a series of affirmative steps is required to access specific material." Justice Stevens dissented from the Court's decision in United States v. American Library Association , which upheld provisions of the Children's Internet Protection Act (CIPA) prohibiting the receipt of federal assistance for Internet access by public libraries that failed to install software to filter pornographic images. Justice Stevens argued that the provision mandated, paradoxically, "underblocking" and "overblocking" of websites. Technology, at the time, could only filter text on a web page; therefore, if a website contained only indecent or pornographic images, the filtering software would not block it. This was Justice Stevens's reason for finding an "underblocking" problem. The "overblocking" issue also arose out of the software's heavy reliance on words, because words chosen for blocking could be pornographic in one context, but scientific, educational, or innocuous in another. Stevens explained, "[in] my judgment, a statutory blunderbuss that mandates this vast amount of 'overblocking' abridges the freedom of speech protected by the First Amendment." Stevens was also troubled by the fact that if even one computer with Internet access in a public library was not equipped with the filtering software, regardless of whether that computer was funded in part by federal assistance, the public library would be ineligible for federal funds. Justice Stevens exhibited his belief that government attempts to ban particular types of content require more exacting scrutiny in the opinions that he wrote related to regulation of adult establishments. In Young v. American Mini-Theaters, Inc. , Stevens authored the opinion for the Court upholding a local ordinance requiring movie theaters that predominantly exhibit adult movies to be a certain distance away from one another. Stevens noted that even when speech is protected, differences in content may permit different government responses.