<P> The basic principle behind government's regulation of the bar has greater power to regulate the speech of lawyers . A balancing test is employed when the Court considers attorney speech . This test weighs the "interest against the State's legitimate interest in regulating the activity in question (with) the interests of the attorney". Thus, while commercial advertising by lawyers is generally protected, rules of professional conduct and ethical guidelines are still permitted . </P> <P> With respect to the United States Military, the federal government has extremely broad power to restrict the speech of military officers, even if such a restriction would be invalid with a civilian . The Supreme Court affirmed this principle in Parker v. Levy (1974) when the Court held the military was essentially a "specialized society from civilian society", which necessitated stricter guidelines . Since Parker, there have been few cases to issue more specific limits on the government's control of military expression . </P> <P> When the government acts as controller of prisons, it has broad abilities to limit the free speech of inmates . Essentially any restriction that is "reasonably related to legitimate penological interests" is valid . This broad power also extends to pretrial detainees and even convicts who are on probation or parole . The only limit recognized by the Court is that the prison must provide an "alternate means of exercising that right" of speech, an alternate channel, that still allows legitimate speech to be expressed . </P> <P> The government may not criminally punish immigrants based on speech that would be protected if said by a citizen . On entry across borders, the government may bar non-citizens from the United States based on their speech, even if that speech would have been protected if said by a citizen . Speech rules as to deportation, on the other hand, are unclear . Lower courts are divided on the question, while the leading cases on the subject are from the Red Scare . </P>

Which of the following types of speech is not protected by the first amendment