Columbia Broadcasting System, Inc. v. Democratic National Committee

Mr. Justice Stewart,

concurring.

While .1 join Parts I and II of the Court’s opinion, and the opinion in Part III, my views closely approach those expressed by Mr. Justice Douglas concurring in the judgment.

*133The First Amendment prohibits the Government from imposing controls upon the press.1 Private broadcasters are surely part of the press. United States v. Paramount Pictures, Inc., 334 U. S. 131, 166. Yet here the Court of Appeals held, and the dissenters today agree, that the First Amendment requires the Government to impose controls upon private broadcasters — in order to preserve First Amendment “values.” The appellate court accomplished this strange convolution by the simple device of holding that private broadcasters are Government. This is a step along a path that could eventually lead to the proposition that private newspapers “are” Government. Freedom of the press would then be gone. In its place we would have such governmental controls upon the press as a majority of this Court at any particular moment might consider First Amendment “values” to require. It is a frightening specter.

I

There is some first-blush appeal in seeking out analogies from areas of the law where governmental involvement on the part of otherwise private parties has led the Court to hold that certain activities of those parties were tantamount to governmental action.2 The evolution of the “state action” concept under the Fourteenth Amendment is one available analogy.3 Another is the decision of this *134Court in Public Utilities Comm’n v. Poliak, 343 U. S. 451, where a policy of a privately owned but publicly regulated bus company that had been approved by the regulatory commission was held to activate First Amendment review. The First Amendment has also been held applicable where private parties control essentially public forums. Amalgamated Food Employees v. Logan Valley Plaza, 391 U. S. 308, Marsh v. Alabama, 326 U. S. 501; cf. Lloyd Corp. v. Tanner, 407 U. S. 551.

The problem before us, however, is too complex to admit of solution by simply analogizing to cases in very different areas. For we deal here with the electronic press, that is itself protected from Government by the First Amendment.4 Before woodenly accepting analogies from cases dealing with quasi-public racial discrimination, regulated industries other than the press, or “company towns,” we must look more closely at the structure of broadcasting and the limits of governmental regulation of licensees.

When Congress enacted the Radio Act of 1927, 44 Stat. 1162, and fóllowed it with the Federal Communications Act of 1934, 48 Stat. 1064, 47 U. S. C. § 151 et seq., it was responding to a then-evident need to regulate access to the public airwaves. Not every member of the public could broadcast over the air as he chose, since the scarcity *135of frequencies made this a sure road to chaos.5 The system selected by the Congress was a hybrid. The Federal Radio Commission (succeeded by the Federal Communications Commission), was to license broadcasters for no more than three-year periods. 47 U. S. C. § 307 (d). The licensees, though subject to some public regulation, were to be private companies.

Scarcity meant more than a need to limit access. Because access was to be limited, it was thought necessary for the regulatory apparatus to take into account the public interest in obtaining “the best practicable service to the community reached by his [the licensee’s] broadcasts.” FCG v. Sanders Brothers Radio Station, 309 U. S. 470, 475. Public regulation has not, then, been merely a matter of electromagnetic engineering for the sake of keeping signals clear. It has also included some regulation of programming. Writing in defense of Commission regulations regarding chain broadcasting, Mr. Justice Frankfurter said: “These provisions [of the Act], individually and in the aggregate, preclude the notion that the Commission is empowered to deal only with technical and engineering impediments to the ‘larger and more effective use of radio in the public interest.’ ” National Broadcasting Co. v. United States, 319 U. S. 190, 217.

Over time, federal regulation of broadcasting in the public interest has been extensive, and, pro tanto, has rightly or wrongly been held to be tolerable under the First Amendment. We now have the Fairness Doctrine, with its personal-attack, editorial-reply, and fair-coverage-of-controversial-issue requirements.6 In Red Lion Broad*136casting Co. v. FCC, 395 U. S. 367, this Doctrine was held to constitute permissible governmental regulation of broadcasters, despite the First Amendment. The Court said:

“Where there are substantially more individuals who want to broadcast than there are frequencies to allocate, it is idle to posit an unabridgeable First Amendment right to broadcast comparable to the right of every individual to speak, write, or publish. . . .
. . Because of the scarcity of radio frequencies, the Government is permitted to put restraints on licensees in favor of others whose views should be expressed on this unique medium. But the people as a whole retain their interest in free speech by radio and their collective right to have the medium function consistently with the ends and purposes of the First Amendment. It is the right of the viewers and listeners, not the right of the broadcasters, which is paramount.” Id., at 388, 390.

The Fairness Doctrine has been held applicable to paid advertising as well as to other programming, Banzhaf v. FCC, 132 U. S. App. D. C. 14, 405 F. 2d 1082. And the public interest in broadcasting has been recognized as a rationale for liberalized standing on the part of listener *137groups in Commission licensing proceedings. Office of Communication of United Church of Christ v. FCC, 123 U. S. App. D. C. 328, 359 F. 2d 994.

Throughout this long history of regulation, however, it has been recognized that broadcasters retain important freedoms, and that the Commission's regulatory power has limits. Quite apart from what may be required by the First Amendment itself, the regulatory legislation makes clear what some of these freedoms are. Section 3 (h) of the Act, 47 U. S. C. § 153 (h), provides that broadcasters are not to be treated as common carriers. Were broadcasters common carriers within the meaning of the Act, they would be subject to 47 U. S. C. §§ 201, 202. Section 201 provides, in pertinent part, that:

“(a) It shall be the duty of every common carrier engaged in interstate or foreign communication by wire or radio to furnish such communication service-upon reasonable request therefor . . . .”

Section 202 provides that:

“(a) It shall be unlawful for any common carrier to make any unjust or unreasonable discrimination in charges, practices, classifications, regulations, facilities, or services for or in connection with like communication service, directly or indirectly, by any means or device, or to make or give any undue or unreasonable preference or advantage to any particular person, class of persons, or locality, or to subject any particular person, class of persons, or locality to any undue or unreasonable prejudice or disadvantage.”

The Act also specifically gives licensees “freedom of speech”:

“Nothing in this chapter shall be understood or construed to give the Commission the power of censorship over the radio communications or signals *138transmitted by any radio station, and no regulation or condition shall be promulgated or fixed by the Commission which shall interfere with the right of free speech by means of radio communication.” 47 TJ. S. C. § 326.

Thus, when examined as a whole, the Federal Communications Act establishes a system of privately owned broadcast licensees. These licensees, though regulated by the Commission under a fairly broad “public interest” standard, have, quite apart from whatever additional protections the First Amendment may provide, important statutory freedoms in conducting their programming.

In Red Lion, supra, this Court held that, despite the First Amendment, the Commission may impose a so-called Fairness Doctrine upon broadcasters, requiring them to present balanced coverage of various and conflicting views on issues of public importance. I agreed with the Court in Red Lion, although with considerablé doubt, because I thought that that much Government regulation of program content was within the outer limits of First Amendment tolerability. Were the Commission to require broadcasters to accept some amount of editorial advertising as part of the public interest mandate upon which their licenses are conditional, the issue before us would be in the same posture as was the Fairness Doctrine itself in Red Lion, and we would have to determine whether this additional governmental control of broadcasters was consistent with the statute and tolerable under the First Amendment. Here, however, the Commission imposed no such requirement, but left private broadcasters free to accept or reject such advertising as they saw fit. The Court of Appeals held that the First Amendment compels the Commission to require broadcasters to accept such advertising, because it equated broadcaster action with governmental action.' *139This holding not only raises a serious statutory question under § 3 (h) of the Act, which provides that broadcasters are not common carriers, but seems to me to reflect an extraordinarily odd view of the First Amendment.

The dissenting opinion today argues, in support of the decision of the Court of Appeals, that only a limited right of access is sought by the respondents and required by the First Amendment, and that such a limited right would not turn broadcasters into common carriers. The respondents argue, somewhat differently, that the Constitution requires that only “responsible” individuals and groups be given the right to purchase advertising. These positions are said to be arrived at by somehow balancing “competing First Amendment values.” But if private broadcasters are Government, how can the First Amendment give only a limited right to those who would speak? Since when has the First Amendment given Government the right to silence all speakers it does not consider “responsible?”

The First Amendment protects the press from governmental interference; it confers no analogous protection on the Government.7 To hold that broadcaster action is governmental action would thus simply strip broadcasters of their own First Amendment rights. They would be obligated to grant the demands of all citizens to be heard over the air, subject only to reasonable regulations as to “time, place and manner.” Cf. Police Dept, of Chicago v. Mosley, 408 U. S. 92, 98; Cox v. Louisiana, *140379 U. S. 536, 554; Poulos v. New Hampshire, 345 U. S. 395; Cox v. New Hampshire, 312 U. S. 569. If, as the dissent today would have it, the proper analogy is to public forums8- — that is, if broadcasters are Government for First Amendment purposes — then broadcasters are inevitably drawn to the position of common carriers. For this is precisely the status of Government with respect to public forums — a status mandated by the First Amendment.9

To hold that broadcaster action is governmental action would thus produce a result wholly inimical to the broadcasters' own First Amendment rights, and wholly at odds with the broadcasting system established by Congress and with our many decisions10 approving those legislative *141provisions.11 As Judge McGowan wrote, dissenting from the judgment of the Court of Appeals in these cases,

“This is the system which Congress has, wisely or not, provided as the alternative to public ownership and operation of radio and television communications facilities. This approach has never been thought to be other than within the permissible limits of constitutional choice.” 146 U. S. App. D, C. 181, 205, 450 F. 2d 642, 666.

II

Part IV of the Court’s opinion, as I understand it, seems primarily to deal with the respondents’ statutory argument — that the obligation of broadcasters to operate in the “public interest” supports the judgment of the Court of Appeals. Yet two of my concurring Brethren understand Part IY as a discussion of the First Amendment issue that would exist in these cases were the action of broadcasters to be equated with governmental action. So, according to my Brother Blackmun, “the governmental action issue does not affect the outcome of this case.” Post, at 148. The Court of Appeals also conflated the constitutional and statutory issues in these cases. It reasoned that whether its decision “is styled as a 'First Amendment decision’ or as a decision interpreting the fairness and public interest requirements 'in light of the First Amendment’ matters little.” 146 U. S. App. D. C., at 188, 450 F. 2d, at 649.

*142I find this reasoning quite wrong and wholly disagree with it, for the simple reason that the First Amendment and the public interest standard of the statute are not coextensive. The two are related in the sense that the Commission could not “in the public interest” place a requirement on broadcasters that constituted a violation of their First Amendment rights. The two are also related in the sense that both foster free speech. But we have held that the Commission can under the statute require broadcasters to do certain things “in the public interest” that the First Amendment would not require if the broadcasters were the Government. For example, the Fairness Doctrine is an aspect of the “public interest” regulation of broadcasters that would not be compelled or even permitted by the First Amendment itself if broadcasters were the Government.12

If the “public interest” language of the statute were intended to enact the substance of the First Amendment, a discussion of whether broadcaster action is governmental action would indeed be superfluous. For anything that Government could not do because of the First Amendment, the broadcasters could not do under the statute. But this theory proves far too much, since it would make the statutory scheme, with its emphasis on *143broadcaster discretion and its proscription on interference with “the right of free speech by means of radio communication,” a nullity. Were the Government really operating the electronic press, it would, as my Brother Douglas points out, be prevented by the First Amendment from selection of broadcast content and the exercise of editorial judgment. It would not be permitted in the name of “fairness” to deny time to any person or group on the grounds that their views had been heard “enough.” Yet broadcasters perform precisely these functions and enjoy precisely these freedoms under the Act. The constitutional and statutory issues in these cases are thus quite different.

In evaluating the statutory claims, the starting point must be the “venerable principle that the construction of a statute by those charged with its execution should be followed unless there are compelling indications that it is wrong . . . .” Red Lion, 395 U. S., at 381.

Though I have no doubt that the respondents here were attempting to communicate what they considered to be important messages, it does not follow that the Commission erred when it refused to require every broadcaster to communicate those messages. Contrary to what is said in dissent today, it is not the case that a seller of goods is granted instant access to the media, while someone “seeking to discuss war, peace, pollution, or the suffering of the poor is denied this right to speak.” Post, at 200. There is no indication that the thousands of broadcasters regulated by the Commission have anything like a uniform policy of turning down “controversial” or “editorial” advertising. In the cases before us, the Business Executives’ spot advertisements were rejected by a single radio station. Of the three television networks, only one turned down the Democratic National Committee’s request for air time. We are told that many, if not most, broadcasters do accept advertising of *144the type at issue here. This variation in broadcaster policy reflects the very kind of diversity and competition that best protects the free flow of ideas under a system of broadcasting predicated on private management.13

Even though it would be in the public interest for the respondents’ advertisements to be heard, it does not follow that the public interest requires every broadcaster to broadcast them. And it certainly does not follow that the public interest would be served by forcing every broadcaster to accept any particular kind of advertising. In the light of these diverse broadcaster policies — and the serious First Amendment problem that a contrary ruling would have presented — there are surely no “compelling indications” that the Commission misunderstood its statutory responsibility.

Ill

There is never a paucity of arguments in favor of limiting the freedom of the press. The Court of Appeals concluded that greater Government control of press freedom is acceptable here because of the scarcity of frequencies for broadcasting. But there are many more broadcasting stations than there are daily newspapers.14 And it *145would require no great ingenuity to argue that newspapers too are Government. After all, newspapers get Government mail subsidies and a limited antitrust immunity.15 The reasoning of the Court of Appeals would then lead to the conclusion that the First Amendment requires that newspapers, too, be compelled to open their pages to all comers.

Perhaps I overstate the logic of the opinion of the Court of Appeals. Perhaps its “balancing” of First Amendment “values” would require no more than that newspapers be compelled to give “limited” access to dissident voices, and then only if those voices were “responsible.” And perhaps it would require that such access be compelled only when there was a single newspaper in a particular community. But it would be a close question for me which of these various alternative results would be more grossly violative of the First Amendment’s guarantee of a free press. For that guarantee gives every newspaper the liberty to print what it chooses and reject what it chooses, free from the intrusive editorial thumb of Government.

I profoundly trust that no such reasoning as I have attributed to the Court of Appeals will ever be adopted by this Court. And if I have exaggerated, it is only to make clear the dangers that beset us when we lose sight of the First Amendment itself, and march forth in blind pursuit of its “values.”

Those who wrote our First Amendment put their faith in the proposition that a free press is indispensable to a free society. They believed that “fairness” was far too fragile to be left for a Government bureaucracy to accom*146plish. History has many times confirmed the wisdom of their choice.

This Court was persuaded in Red Lion to accept the Commission’s view that a so-called Fairness Doctrine was required by the unique electronic limitations of broadcasting, at least in the then-existing state of the art. Rightly or wrongly, we there decided that broadcasters’ First Amendment rights were “abridgeable.” But surely this does not mean that those rights are nonexistent. And even if all else were in equipoise, and the decision of the issue before us were finally to rest upon First Amendment “values” alone, I could not agree with the Court of Appeals. For if those “values” mean anything, they should mean at least this: If we must choose whether editorial decisions are to be made in the free judgment of individual broadcasters, or imposed by bureaucratic fiat, the choice must be for freedom.

U. S. Const., Amdt. I, provides, in pertinent part, that “Congress shall make no law . . . abridging the freedom of speech, or of the press . . . .”

See Amalgamated Food Employees v. Logan Valley Plaza, 391 U. S. 308; Railway Employes’ Dept. v. Hanson, 351 U. S. 225; Public Utilities Comm’n v. Poliak, 343 U. S. 451; Marsh v. Alabama, 326 U. S. 501.

“Conduct that is formally 'private’ may become so entwined with governmental policies or so impregnated with a governmental *134character as to become subject to the constitutional limitations placed upon state action.” Evans v. Newton, 382 U. S. 296, 299. Earlier, in Burton v. Wilmington Parking Authority, 365 U. S. 715, the Court held that a privately owned restaurant located within a public parking garage was sufficiently involved with state authority to bring its racially discriminatory actions within the proscription of the Fourteenth Amendment.

See, e. g., United States v. Paramount Pictures, Inc., 334 U. S. 131, 166. The Federal Communications Act also prohibits the Commission from interfering with “the right of free speech by means of radio communication.'’ 47 U. S. C. § 326.

For a history of regulatory legislation regarding broadcasters, see Red Lion Broadcasting Co. v. FCC, 395 U. S. 367, 375-386; National Broadcasting Co. v. United States, 319 U. S. 190, 210-214.

The personal-attack and editorial-reply rules appear at 47 CFR §§ 73.123, 73.300, 73.598, 73.679. The public issue aspect of the *136Fairness Doctrine requires the broadcaster to give adequate coverage to public issues, fairly reflecting divergent views. United Broadcasting Co., 10 F. C. C. 515; New Broadcasting Co., 6 P & F Radio Reg. 258; see generally Applicability of the Fairness Doctrine in the Handling of Controversial Issues of Public Importance, 29 Fed. Reg. 10415. This coverage must be provided at the broadcaster’s own expense if necessary, Cullman Broadcasting Co., 25 P & F Radio Reg. 895, and the duty must be met by providing programming obtained at the licensee’s own initiative if it is available from no other source. John J. Dempsey, 6 P & F Radio Reg. 615.

Government is not restrained by the First Amendment from controlling its own expression, cf. New York Times Co. v. United States, 403 U. S. 713, 728-729 (Stewart, J., concurring). As Professor Thomas Emerson has written, “The purpose of the First Amendment is to protect private expression and nothing in the guarantee precludes the government from controlling its own expression or that of its agents.” The System of Freedom of Expression 700 (1970).

“[T]he right to speak can flourish only if it is allowed to operate in an effective forum — whether it be a public park, a schoolroom, a town meeting hall, a soapbox, or a radio and television frequency." Post, at 193.

Professor Emerson has recognized the scope of the “access” argument: “The licensee therefore can only be considered as the agent of the government, or trustee of the public, in a process of further allocation. Hence the licensee would have no direct First Amendment rights of his own, except as to his own expression.” Supra, n. 7, at 663.

Though the licensee would be free to say what it wished during its own broadcasting, whatever that might mean, it seems clear that the licensee would have no special claim to broadcast time and would lose entirely the freedom to program and schedule according to its own judgment, values, and priorities. Cf. Police Dept, of Chicago v. Mosley, 408 II. S. 92, 98; Cox v. Louisiana, 379 U. S. 536, 554; Poulos v. New Hampshire, 345 U. S. 395; Cox v. New Hampshire, 312 U. S. 569. Licensees would be forced to develop a procedurally fair and substantively nondiscriminatory system for controlling access, and in my view this is precisely what Congress intended to avoid through § 3 (h) of the Act.

Bed Lion Broadcasting Co. v. FCC, 395 U. S. 367; National Broadcasting Co. v. United States, 319 U. S. 190; FCC v. Sanders Brothers Radio Station, 309 U. S. 470; FCC v. Pottsville Broadcasting Co., 309 U. S. 134.

None of this suggests any disagreement on my part with the evolution of “state action” under the Fourteenth Amendment. I recognize that if Moose Lodge No. 107 v. Irvis, 407 U. S. 163, were relevant, the fact that the Commission considered and rejected a challenge to broadcaster policy might be sufficient to constitute “state action.” This, in fact, was the basis of the Court’s decision in Public Utilities Comm’n v. Poliak, 343 U. S. 461.

The basis for a Fairness Doctrine is statutory, not constitutional. As the Court said in Red Lion:

“In light of the fact that the ‘public interest’ in broadcasting clearly encompasses the presentation of vigorous debate of controversial issues of importance and concern to the public; the fact that the FCC has rested upon that language from its very inception a doctrine that these issues must be discussed, and fairly; and the fact that Congress has acknowledged that the analogous provisions of § 315 are not preclusive in this area, and knowingly preserved the FCC’s complementary efforts, we think the fairness doctrine and its component personal attack and political editorializing regulations are a legitimate exercise of congressionally delegated authoritjC’ 395 U. S., at 385.

The Democratic National Committee cited this very lack of uniformity as a reason for seeking a declaratory ruling from the Commission. There was too much diversity, it thought, for it to plan effectively an advertising campaign. In the DNC’s request for a declaratory ruling before the Commission, it stated:

“In addition to the three national commercial networks, as of April 1, 1970, there were, on the air, 509 commercial VHF television stations, 180 commercial UHF stations, 4,280 standard broadcast stations, and 2,111 commercial FM stations. While several of these stations have common owners, it does not necessarily follow that every station owned by an individual or group would follow the same policies.”

There are 1,792 daily newspapers in the United States. Ayer Directory of Publications vm (1973). Compare the number of broadcasters, n. 13, supra.

Newspapers and other periodicals receive a Government subsidy in the form of second-class postage rates, 39 CFR § 132. An antitrust immunity is established by the Newspaper Preservation Act, 15 U. S. C. § 1801 et seq.