Inc. v. Federal Communications Commission Denver Area Educational Telecommunications Consortium

The Court's decision in Denver Area Consortium will likely have little impact outside the area of cable television regulation. About one year after the Court's decision the Court unanimously found similar restrictions on indecent material on the Internet to violate the First Amendment in Reno v. American Civil Liberties Union (1997). In Reno, the Court unanimously applied the strict scrutiny test, not mentioning Justice Breyer's contextual approach and barely even citing its decision in Denver Area Consortium. Although lower federal courts have attempted to apply the various approaches taken in the case to other cable television regulations, it appears that outside this limited area the Court's decision will have little, if any, impact.