ms. strossen: to be sure, justice breyer is generally less speech protective than other justices because he issues categorical rules which tend to be speech protective. in raid, he reiterated his unique view that content-based speech regulations should not automatically trigger strict me. in walker, ironically, justice breyer's majority opinion did base itself specifically on a formal categorical rule. namely that once speech is categorized as government expression, it is completely exempt from the first amendment. to heighten the irony, the last time this court discussed the government speech exception as they called it the newly minted government speech exception from first amendment protection was 2009 in a case where justice breyer had disavowed precisely this categorical approach to government speech, which he then supports ironically in the walker case. in 2009, justice breyer concurred -- on the understanding that the government speech doctrine, to indicate he doesn't think it's a fixed doctrine, as a rule of psalm, not a rigid category. even more pointedly in his concurrence, he