Editing Symbolic speech (section)

===''Spence v. Washington''===
{{main|Spence v. Washington}}
A college student had hung a U.S. flag on his window, upside down and adorned with peace signs, in May 1970 as to protest the government's actions in [[Cambodian campaign|the invasion of Cambodia]] and the [[Kent State shootings]]. He was arrested and convicted under a Washington state statute that barred "improper use" of the flag, including adorning it with decorations. The Supreme Court ruled ''per curiam'' that the statute was unconstitutional as it did not consider the intent of speech of displaying the flag. In the opinion, the Court devised a two-prong test to determine if actions can qualify for First Amendment protections: "An intent to convey a particularized message was present, and in the surrounding circumstances the likelihood was great that the message would be understood by those who viewed it.". This doctrine became known as the ''Spence'' test.<ref name="caitlin">{{cite journal | last = Housley | first = Caitlin | title =A Uniform Test Isn't Here Right Now, but Please Leave a Message: How Altering the Spence Symbolic Speech Test Can Better Meet the Needs of an Expressive Society | journal = [[Kentucky Law Journal]] | volume = 103 | pages = 657 | year = 2014 }}</ref>