Valentine v. Chrestensen, 316 U.S. 52 (1942), was a case in which the Supreme Court of the United States ruled that commercial speech in public thoroughfares is not constitutionally protected.

[1][2] Respondent F. J. Chrestensen was the owner of the USS S-49, a World War I submarine that he had moored at a State pier on the East River in New York City.

[2] Accordingly, Chrestensen remade his handbill by removing the admission fee from the front side and placing on the reverse a protest against the City Dock Department's refusal to grant his submarine dockage.

The Police Department nevertheless prohibited distribution of the new handbill on grounds that the front side retained commercial advertising content, even without statement of an admission fee.

The Supreme Court reversed the Second Circuit's ruling, finding that, although states and municipalities may not unduly burden free expression in the streets, the Constitution did not prevent the government from regulating purely commercial advertising.