individuals’ involvement. In Walker, the Court held that specialty automobile license plates issued by Texas were government speech over which the government could exercise editorial control. The Court cited three factors underlying its conclusion: (1) “the history ,of license plates show[ed] that ... they long ha[d] communicated messages from the States,” id. at 2248; (2) “license plate designs [we]re often closely identified in the public mind with the [State],” id. (internal quotation marks omitted); and (3) “Texas maintain[ed] control over the messages conveyed on its specialty plates,” id. at 2249. Applying a similar framework, the- Court has also found to be government speech a city’s refusal to place a private group’s permanent religious m Y., 196 F.3d 458, 468-69 (2d Cir. 1999) (<HOLDING>). In its recent decision in Matal, the Supreme
holding that an expert established a national standard of care for police officer training by testifying that police departments throughout the country commonly trained officers to deal with mentally distuibed persons and by naming several departments that offered such training holding the evidence supported the police officers failure to follow the directives in the montgomery county police departments field operations manual holding that a police departments refusal to permit police affin ity group to march in parades was not a form of government speech holding that fire departments are analogous to police departments in this respect holding that police officers criticism of his departments handling of a sniper incident was protected speech because the officer spoke in his capacity as police union president