In the United States, the Supreme Court has not issued a direct ruling on whether speech codes at public universities are unconstitutional. However, the United States District Court for the Eastern District of Michigan has struck down a speech code at the University of Michigan, indicating that broad speech codes seeking to prohibit hate speech probably violate the First Amendment ("Doe v. University of Michigan," 1989). Subsequent challenges against such language as part of harassment policies, diversity mandates, and so forth instead of being self-identified as speech codes have generally succeeded to date.