Since its inception, the public forum doctrine has maintained a byzantine existence. The Supreme Court has struggled to define the extent to which the First Amendment protects expressive activities in public places. Prior to developing a public forum doctrine, the Court used various means to limit government restrictions of expressive uses of public property. Since 1972, however, the Court has increasingly relied on categorical approaches to determine when members of the general public can use government-controlled property for communicative purposes.
Stephen K. Schutte,
International Society for Krishna Consciousness, Inc. v. Lee: The Public Forum Doctrine Falls to a Government Intent Standard, 23 Golden Gate U. L. Rev.