<P> Restrictions that require examining the content of speech to be applied must pass strict scrutiny . </P> <P> Restrictions that apply to certain viewpoints but not others face the highest level of scrutiny, and are usually overturned, unless they fall into one of the court's special exceptions . An example of this is found in the United States Supreme Court's decision in Legal Services Corp. v. Velazquez in 2001 . In this case, the Court held that government subsidies cannot be used to discriminate against a specific instance of viewpoint advocacy . </P> <P> The Court pointed out in Snyder v. Phelps (2011) that one way to ascertain whether a restriction is content - based versus content - neutral is to consider if the speaker had delivered a different message under exactly the same circumstances: "A group of parishioners standing at the very spot where Westboro stood, holding signs that said' God Bless America' and' God Loves You,' would not have been subjected to liability . It was what Westboro said that exposed it to tort damages ." </P> <P> Grayned v. City of Rockford (1972) summarized the time, place, manner concept: "The crucial question is whether the manner of expression is basically incompatible with the normal activity of a particular place at a particular time ." Time, place, and manner restrictions must withstand intermediate scrutiny . Note that any regulations that would force speakers to change how or what they say do not fall into this category (so the government cannot restrict one medium even if it leaves open another). Ward v. Rock Against Racism (1989) held that time, place, or manner restrictions must: </P>

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