Does the "efficient conduct of business operations" constitute a significant governmental interest justifying limits on free speech?

MultiRegion, United States of America

The following excerpt is from Bland v. Fessler, 79 F.3d 942 (9th Cir. 1996):

13 Although Van Bergen also held that the "efficient conduct of business operations" is a significant governmental interest justifying limits on free speech, 59 F.3d at 1554, we view this rationale with caution and skepticism. See Waters v. Churchill, --- U.S. ----, ----, 114 S.Ct. 1878, 1888, 128 L.Ed.2d 686 (1994) ("The government cannot restrict the speech of the public at large just in the name of efficiency.").

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