Turner Broadcasting System, Inc. v. Federal Communications Commn.
512 U.S. 622 (1994)
The Cable Television
Consumer Protection and Competition Act of 1992 required cable television systems to set aside some of their
channels for local programming. This was known as the 'must carry' rule.
The idea was to keep local
broadcast stations in business to retain diversity.
Local channels that
broadcast over the air couldn't compete with the quality and reliability
of cable systems, so they tended to lose market share when cable tv was
available.
On the other hand, it forced
cable systems to carry stations they didn't want to carry.
Turner sued, claiming that the
law was a violation of the 1st Amendment right to free speech.
Turner argued that they
should be allowed to carry whatever channels they wanted, and to force
them not to was an infringement of free speech.
Cable tv stations argued
that for every broadcast station that was added, one cable station would
have to be dropped, and that wasn't fair to them.
The US Supreme Court found
that content-neutral laws are
required to meet intermediate scrutiny.
The US Supreme Court found
that the law was content-neutral
in that it didn't discriminate based on message, ideas, subject matter,
or content.
The law didn't say that you
had to carry any particular kind of station, or broadcast a particular
kind of message.
For example, if the law
required a company to carry a religious channel, then it would not be content-neutral.
The Court found that content-neutral laws are subject to intermediate
scrutiny.
Intermediate scrutiny requires that the law involved important
governmental interests that are furthered by substantially related means
for it to not be a violation of the 1st Amendment.
The Court remanded the case
to see if it met intermediate scrutiny.
The case came back up to the
US Supreme Court (520 U.S. 180 (1997)), and the Court found that the law
did indeed meet intermediate scrutiny
and was therefore not a violation of the 1st Amendment.
"A content-neutral
regulation will be sustained under the 1st Amendment if it advances important governmental
interests unrelated to the suppression of free speech and does not burden
substantially more speech than necessary to further those
interests."