<P> Along with communicative restrictions, less protection is afforded for uninhibited speech when the government acts as subsidizer or speaker, is an employer, controls education, or regulates the mail, airwaves, legal bar, military, prisons, and immigration . </P> <P> The Supreme Court has held that "advocacy of the use of force" is unprotected when it is "directed to inciting or producing imminent lawless action" and is "likely to incite or produce such action". In Brandenburg v. Ohio (1969), the Supreme Court unanimously reversed the conviction of a Ku Klux Klan group for "advocating...violence...as a means of accomplishing political reform" because their statements at a rally did not express an immediate, or imminent intent to do violence . This rule amended a previous decision of the Court, in Schenck v. United States (1919), which simply decided that a "clear and present danger" could justify a congressional rule limiting speech . The primary distinction is that the latter test does not criminalize "mere advocacy". </P> <P> In 2017, a juvenile court in Massachusetts ruled that repeatedly encouraging someone to commit suicide was not protected by the First Amendment, and found a 20 - year - old woman, who was 17 at the time, guilty of manslaughter on this basis . The judge cited a little - known 1816 precedent . The woman is expected to file an appeal . </P> <P> In Gertz v. Robert Welch, Inc. (1974), the Supreme Court decided that there is "no constitutional value in false statements of fact". However, this is not a concrete rule as the Court has struggled with how much of the "speech that matters" can be put at risk in order to punish a falsehood . </P>

What types of speech are not protected by the first amendment