The simple principle has broad implications, and has led to contentious disputes within the Supreme Court.
[1] The doctrine was implied in Wooley v. Maynard in 1977 when the Supreme Court acknowledged a legitimate government interest in communicating an official, ideologically partial message to the public.
In the 1991 case of Rust v. Sullivan,[4] government-funded doctors in a government health program were not allowed to advise patients on obtaining abortions, and the doctors challenged this law on Free Speech grounds.
[1] However, the Court held that because the program was government-funded, the doctors were, therefore, speaking on behalf of the government.
"[5] In Legal Services Corp. v. Velazquez, the Supreme Court held that, although, providing government-funded legal services appeared similar to government-funded doctors, the speech of the lawyers was private speech because lawyers spoke on behalf of their clients.