Editing Symbolic speech (section)

===''Texas v. Johnson''===
{{main|Texas v. Johnson}}
In 1984, during a protest against the policies of the [[Presidency of Ronald Reagan|Reagan administration]] in Dallas, Texas, Gregory Lee Johnson doused an [[Flag of the United States|American flag]] that was given to him by a fellow demonstrator with kerosene and [[Flag Burning|set it alight]] while those around him chanted "America the red, white and blue, we spit on you." He was later arrested and convicted on a flag desecration law in Texas, and sentenced to one year in prison and a $2,000 fine. 
The court ruled 5 to 4 in favor of Johnson. Building upon ''Spence'', Justice [[William J. Brennan, Jr.|Brennan]] wrote that because such other actions in relation to the flag (such as saluting, and displaying) are considered to be a form of expression, so must too the burning be, and that Johnson's protest was "'Sufficiently imbued with elements of communication' to implicate the First Amendment." He also explained that the relevance of the ''O'Brien'' test is limited "in which 'the governmental interest is unrelated to the suppression of free expression'", as the Texas law in question had its interest in preventing any violent reaction that may spring from those witnessing the burning of the flag. This case helped solidify the condition that any law that inhibits freedom of speech must have an important and compelling interest to do so.<ref name="amazon.com">[[Lee Epstein|Epstein, Lee]] and Walker, Thomas G. (1998) "Constitutional Law for a Changing America: rights, liberties, and justice" 3rd ed. pp. 258-280 Washington D.C.: Congressional Quarterly Inc. [https://www.amazon.com/dp/1933116803]</ref>