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Private Speech, Public Purpose: The Role of Governmental Motive in First Amendment Doctrine

In one of the most frequently quoted passages of one of the most frequently cited First Amendment decisions, the Supreme Court declared that "the purpose of Congress ... is not a basis for declaring [ ] legislation unconstitutional."1 Noting several hazards of attempting to ascertain legislative motive, the Court in United States v O'Brien2 eschewed this endeavor in First Amendment cases, as well as in other constitutional adjudication. It was no task of the judiciary to discover or condemn "illicit legislative motive" relating to the freedom of speech; the question for courts was only whether a challenged statute, by its terms or in its application, had an "unconstitutional effect" on First Amendment freedoms.3 In keeping with this approach, most descriptive analyses of First Amendment law, as well as most normative discussions of the doctrine, have considered the permissibility of governmental regulation of speech by focusing on the effects of a given regulation. This focus on effects comes in two standard varieties. In one, the critical inquiry relates to the effect of a regulation on the speaker's ability to communicate a desired message. In the other,