According supporters, there is a long history of legislative and judicial decisions that justifies the "Bellotti" decision. While pre-1900 Supreme Courts believed that corporations did not deserve any protection under the First Amendment, by 1970 some lower courts were beginning to recognize First Amendment protection to "corporate speech." Lawyer Robert Prentice stated that First Amendment protection for corporations has worked its way into the decisions of the Supreme Court since the 1940s, in cases such as "Valentine v. Chrestensen" (1942), "Pittsburgh Press Co. v. Pittsburgh Commission on Human Relations" (1973) and "Virginia State Pharmacy Board v. Virginia Citizens Consumer Council" (1976). From 1973 to Chief Justice Burger's departure in 1986, "the Burger Court ... invalidated every commercial speech ban considered," building up precedents for the "Bellotti" decision.