Editing Symbolic speech (section)

===''Hurley v. Irish-American Gay, Lesbian, and Bisexual Group of Boston''===
{{main|Hurley v. Irish-American Gay, Lesbian, and Bisexual Group of Boston}}
In 1992, an LGBT group was refused to allow to participate in Boston's parade in celebration of [[St. Patrick's Day]] and [[Evacuation Day (Massachusetts)|Evacuation Day]] by the parade organizers, who said the group's identity did not fit the theme of the parade. The Supreme Court unanimously ruled in favor of the organizers, that the message they wanted to convey was expressive speech and protected by the First Amendment, and thus could deny the LGBT group from participation. Justice [[David Souter]] wrote in the opinion that the "particularized message" from ''Spence'' was too limited, and that a "narrow, succinctly articulable message is not a condition of constitutional protection, which if confined to expressions conveying a 'particularized message,' would never reach the unquestionably shielded painting of [[Jackson Pollock]], music of [[Arnold Schoenberg]], or Jabberwocky verse of [[Lewis Carroll]]."<ref name="tomasik" /> ''Hurley''{{'s}} conflict with ''Spence'' and ''Johnson'' created a [[circuit split]] on evaluating symbolic speech for constitutional protection.<ref name="tomasik"/>